PLEASE TAKE NOTICE that upon the annexed affidavit of Samuel H. Sloan sworn to the 28th day of November, 2005, 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
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 motion to disqualify Alexander Karam, Dorchen Leidholdt and Sanctuary for Families from appearing as counsel in this case. This case in its various aspects has been going on for 14 years since 1991. I had first brought Dayawathie Rankoth to America in 1988 on a tourist visa because she was pregnant, in order that she give birth in America to confer American citizenship on our child. I entrusted her to Sister Bernadine Dominick, who ran a home for unwed mothers called the Casa Vincentia in Oakland, California. Dayawathie gave birth to Michael there on June 18, 1988. As Dayawathie was here on a tourist visa, it was necessary to take her back within the time allotted for her visa, so in July, 1988, I took her back to Abu Dhabi where we had been living. On February 10, 1989, after she had been arrested by the police, she flew back to her home in Bowalawatta, Kandy, Sri Lanka, leaving Michael with me. I later made two trips to Sri Lanka to get her out. The first trip in August 1989 I could not get her out because the civil war had reached its peak and all government offices were closed. She became pregnant with out second child, George, on that trip. In November 1989 I made another trip to Sri Lanka and this time I was able to get her out and I brought her to Fujairah, United Arab Emirates, where we were living. As she was pregnant again, I later obtained another tourist visa for her so that she could give birth to our next child in America too.
2. In 1991, we were living in my motherfs house at 917 Old Trents Ferry Road in Lynchburg, Virginia when on or about June 19, 1991, I brought Dayawathie Rankoth who was four months pregnant and our children Michael and George by car to Jamaica Queens. I had business to take care of the following morning, so I arranged for them to stay one night in a hotel and then I planned to take them the following morning back to my motherfs house in Lynchburg, Virginia where we had been staying up until this time. Unfortunately, as I had business to take care of, I was one hour late the following morning to come back to pick them up. Upon arrival I was told that they had been waiting outside for me and had just stepped back inside. I was told that they were just coming down the steps and to wait outside as they would be down in a minute.
3. So I waited and waited and waited. I was told by another resident that Dayawathie and the children had been stopped on their way out the door taken into a office by a Miss Bivins, who had locked the door. The other residents were concerned about this because they did not know what was going on.
4. I continued to wait outside the building for more than 24 hours. I slept in my car. They never came out. Finally, the following afternoon, another resident called out the window that they had been taken out the back door and put in a closed van the previous evening and taken to an unknown location.
5. I spent the next four years looking for them, checking with every possible agency and even walking the streets of New York City trying to locate them. Shortly after their disappearance, I received a telegram from Sebastian Ike of the Child Welfare Agency in New York City who informed me that the CWA was investigating them and was considering starting removal proceedings to take the children away from the mother. However, the CWA had lost track of them too and were unable to find them just as I had been.
6. Just a day or two before their disappearance, I had started a proceeding in New York Family Court because I feared that something like this might happen. There had been prior proceedings in Queens and in Lynchburg, Virginia which had been abandoned. There were several court hearings in New York Family Court over more than one year until October 1992. Each time the judge ordered the whereabouts of the children revealed to him. Each time the agency reported that they were unable to locate the children or that the gsocial workerh had refused to reveal their whereabouts. That gsocial workerh has since been revealed as Sister Theresa Courtney of Sanctuary for Families, who has never been, as far as I am aware, an official of the City of New York.
7. Since Dayawathie had been four months pregnant at the time of her disappearance, I knew the due date of the delivery of her child, Anusha, the same child who is the subject of the proceeding here. At the time of the due date, I started calling every hospital in New York City that delivers babies to see if this child had been born. Finally, I hit pay dirt because St. Vincentfs Hospital informed me that the child had been born there. I have since been wondering why they chose St. Vincentfs Hospital since I now know that Dayawathie never lived anywhere near that hospital.
8. I went to St. Vincentfs Hospital on the pretext of wanting to pay the hospital bill for the birth of the baby. They gave me the bill which showed the address of the mother to be PO Box 413, Times Square Station, New York NY. I went to that post office and filed a Freedom of Information Request for the identity of the holder of that PO Box. This revealed that the holder of this PO Box was Sanctuary for Families.
9. I found out that Sanctuary for Families was located in a church on the corner of 46th Street and Eighth Avenue in New York City. I staked out the church for a while to see if I could see Dayawathie and the children going in or out of there. When that failed, I called the New York City Police and complained that my children and their mother had been kidnapped and were being held prisoner inside. The staff of Sanctuary for Families treated this as a joke. The police searched the place but of course could not find the children.
10. I attempted to file a writ of habeas corpus in New York Supreme Court but the judge refused to sign the writ because I could not provide an actual address for the children. Finally, in 1992 I filed a suit in Federal Court in Brooklyn against Sanctuary for Families alleging a conspiracy to kidnap all of my children. The case was Sloan vs. Pattison, 92 Civil 2388 (EDNY) (RJD). Sanctuary for Families appeared and answered through Lawrence Kamin, Esq. of the prestigious law firm of Willkie, Farr & Gallagher. They filed an answer which essentially denied any knowledge of the whereabouts of the children and their mother. The case was eventually dismissed http://www.samsloan.com/judgego.htm .
11. Finally, in April, 1995, I retained Denise Grey, an investigator who specializes in finding children who have been given away for adoption. Amazingly, she found the children right away. They were living in the South Bronx, at 905 Tinton Avenue.
12. I went to that address and Dayawathie immediately invited me to come in to live with her. She introduced me to Anusha who had been born in the four years that I had been unable to locate the children. Anusha was now three and a half years old and had been told that her father was dead.
13. The children were very surprised to meet their father especially since they had been told that I was dead. George fainted. Dayawathie told me all about Sister Theresa Courtney, about how she had led her out the back door when I had been waiting out the front door. In the intervening four years, Dayawathie had been living in a variety of safe houses, especially one on Allerton Avenue in the North Bronx.
14. I had thought that after all the trouble they had gone to hide the mother and the children from both me and the Child Welfare Administration, that at least they were being kept in a good place. I was proven wrong. They were living in the most horrifying squalor imaginable. There were a million cockroaches on the walls, so many that you could not really see the walls. Their best friends were prostitutes and crack addicts named Julie, Jean and One-Legged Brenda, who lived upstairs. They regularly did business with a loan shark named Panama.
15. The children told me all about Sister Theresa Courtney, who visited them regularly and whom they very much disliked. It was obvious that Sister Theresa Courtney knew the horrifying conditions under which the children were living and was doing nothing about it.
16. I spent two weeks cleaning up Dayawathiefs apartment while living there. Then, I had to go back to California. Dayawathie asked me to take the two boys, Michael and George, with me because they were wild and out of control. She wanted to keep Anusha with her. Naturally, I agreed to take the boys with me. I gave Dayawathie five hundred dollars and she bought the boys new sets of clothing for their trip to California. However, Dayawathie said to me repeatedly gDonft tell Theresah. She said that Theresa would be very angry if she found out that the kids were in California. Naturally, I promised not to tell Theresa.
17. We flew to California and I lived in San Francisco with my two sons Michael and George for one month. We lived at 2550 Webster Street, the Bourn Mansion, a famous building where I was helping the owner with her many court cases. Just as Dayawathie had said, the boys were far more difficult and unruly than I had imagined. They often fought with each other. The owner of the Bourn Mansion wanted to kick them out because they tore up her garden in her back yard. A bigger problem was that Michael refused to go to school. Finally, I took them over to Alameda where their half-sister Jessica was attending the Haight School. I enrolled them in the same school.
18. I was considering moving to the East Bay, where I had attended the University of California at Berkeley. We spent a few nights in Oakland. However, the owner of the Bourn Mansion, Arden Van Upp, called me back to help her with some of her legal work. Just when I got there, Dayawathie called to inform me that Theresa Courtney had found out that the children were in California. The way she had found out was that the Haight School, where I had enrolled the boys, had called the school in the Bronx which the boys had previously attended. However, that school instead of calling Dayawathie had called Theresa Courtney. Dayawathie was upset at this development and said that she was thinking of coming to California.
19. Just as we were talking on the telephone, there was a knock on the door. I answered the door and it was the police, who arrested me. I could not understand what had happened. I had spoken to Dayawathie on the phone every day since I had brought the boys to California. In fact I was talking on the phone to her at the very moment the police came knocking on the door. She was just explaining that the school in the Bronx where Dayawathie was living had informed Theresa that the two boys were in California and were attending school there. This had happened because the school in Alameda, California had contacted the school in the Bronx asking them for a transfer of the student records. The school in the Bronx had apparently breached student confidentially by telling Theresa Courtney that the boys were in California. Dayawathie of course knew that the boys were in California but had kept this information secret from Theresa. Now, Theresa had gone to her lawyer in Manhattan and had a judge in Manhattan issue a writ of habeas corpus to bring the boys back to New York.
20. The question was how a judge in Manhattan was able to do this when Dayawathie and the children were living in the Bronx. The answer is that they gave a FAKE ADDRESS. As Dayawathie explained it to me, the attorney for Sanctuary for Families was a personal friend with a judge in Manhattan. She had called the judge at home at night. The judge agreed to issue the order provided that the case was filed in Manhattan. Now, in order to get jurisdiction in Manhattan they created a fake address. The address was 410 West 40th Street, New York NY 10036. Dayawathie however lived at 905 Tinton Avenue, Bronx NY. She had never lived in Manhattan at that or any other address. I later went to 410 West 40th Street. There is a soup kitchen there operated by a church. I showed the pastor a picture of Dayawathie and the children. He said that he had never seen them before in his life. He said that Sanctuary for Families had rented an apartment upstairs during the period in question, but nobody had ever lived there and he was completely certain that Dayawathie had never been there.
21. In California they have a law which does not exist in New York or in any other state as far as I am aware that a person can be arrested and held gpending investigationh, without any charges being brought. That is how they arrested me. I was never taken to court. I never saw a judge. They put me in jail in San Francisco and then transferred me to Santa Rita County Jail near Oakland. During this time, my two boys, Michael and George, were extradited to New York.
22. I was released in June with no charges ever being brought. As far as I am aware, there is no record of me even being in jail in California. After I got out, I flew back to New York. However, Dayawathie and the children had disappeared again. Sister Theresa Courtney had moved them out of 905 Tinton Avenue and taken them to parts unknown.
23. A writ of habeas corpus should not have been issued by the New York Family Court because of no jurisdiction. Dayawathie had never been awarded legal custody of the children by any court. The previous case in 1991 had been dismissed with no final order entered because Dayawathie had disappeared with the children when Sister Theresa Courtney had hidden them. Michael had been born in Oakland, California so in no way did New York have jurisdiction. Nevertheless, the boys were extradited to New York while I was still in jail. I was released from jail in California. No charge was ever brought against me. I was never even taken before a judge. However, by the time I got out the boys were gone.
24. During the two weeks that I had been living with Dayawathie at 905 Tinton Avenue, she had become pregnant with our fourth child. Upon finding out that Dayawathie was pregnant with our fourth child, Sister Theresa Courtney had arranged for Dayawathie to have an abortion. As Dayawathie later has explained it, Theresa said that since she was a nun in the Roman Catholic Church, she could not personally take Dayawathie to the abortion clinic. Therefore, she arranged for a co-worker to take Dayawathie to the abortion clinic. The abortion was performed on July 7, 1995. I know this date because I later saw documents, including an appointment letter and a bill providing this date, as the date of the abortion.
25. Thus, after I got out of jail after having been arrested by an illegal order, my sons had been extradited to New York and my unborn baby had been aborted. When I went to New York to try to locate Dayawathie again, Theresa had moved her out of the apartment at 905 Tinton Avenue and Dayawathie had disappeared to parts unknown. The case under which the writ of habeas corpus had been issued, No. V-4534/95, was dismissed. I tried to reopen it, without success.
26. Almost immediately after the abortion of July 7, 1995, Dayawathie became pregnant by a passing stranger. As a result, Geeta Rankoth, her fourth child, was born June 9, 1996. Dayawathie believes that the father was named Kamal and he was from Bangladesh but I have asked around in the Bangladesh community and there is no such person from Bangladesh in New York. The result is that instead of having a child with me as the father, Dayawathie had a child by an unknown father. Which is better? Geeta by the way is a wonderful child and I often refer to her as my step-daughter.
27. The problem Theresa now has is that between 1991 and 1995 Dayawathie could not contact me because she did not know where I was and I did not know where she was. However, now, Dayawathie knew where I was and soon she called me and gave me her new address, which was on Ft. Hamilton Parkway near Prospect Park. This was a facility operated by Sanctuary for Families. In July 1996, I went there with my other daughter Jessica, aged 7, and we met Dayawathie, Anusha and the newborn baby Geeta near the subway station and spent the day in Manhattan together. I then went with Jessica to play in the US Open Chess Championship in Alexandria, Virginia. When we got back in New York two weeks later, Dayawathie and the four children had been moved out of the Ft. Hamilton Parkway facility. Apparently, Sister Theresa Courtney had found out that we had met and had moved Dayawathie to another facility.
28. In February, 1997, Dayawathie called me again. She had just been given a new apartment on 1581 Park Avenue, New York NY This is in the Johnson Housing Project at 113th Street and Lexington.. She asked me to move in with her, which I did. We lived together there for several months.
29. Unfortunately, soon thereafter some of the denizens she had left behind in the Bronx found her. By then they had been evicted from their own apartments in the same building, 905 Tinton Avenue, and now they were staying with friends in the project across Lexington Avenue. Soon, they moved into Dayawathiefs apartment. Before long, we had Jean, Julie, Jeans daughter, One-legged Brenda and new comers Brenda Morales and Jimmy all living with me, Dayawathie and the four children in the same two bedroom apartment. As Princess Diana later famously commented, gIt was a bit crowdedg.
30. I tried to convince Dayawathie to lock these people out, but she kept letting them in. They usually came home at about 2 AM. We later found out that Brenda Morales and Jimmy were HIV Positive. This is the reason they could not find any place else to live. Brenda Morales was a professional thief. She would take my children, Anusha and George, to stores and use them as decoys so that she could steal stuff. If she was caught, the police would be reluctant to arrest her because of the two children with her. Dayawathie knew about this but would do nothing to stop it.
31. Julie, Jean and One-Legged Brenda were five-dollar prostitutes, especially One-Legged Brenda. I suspect that she lost her leg to drug addiction. They often smoked Crack. One-Legged Brenda gave birth to a baby and social services immediately took the baby away from the mother. A few days after One-Legged Brenda got back from delivering the baby, I went to sleep in the apartment with nobody but me, Dayawathie and the four children there. I was hoping to have a night of peace. However, I woke up in the middle of the night to find that One-Legged Brenda had crawled into bed with me. Some men would be happy to find a woman in bed with them but I certainly was not happy, especially since I knew that One- Legged Brenda was HIV Positive and a crack addict. Dayawathie had opened the door and let Jean, Julie, Jeanfs daughter and One-Legged into the apartment in the middle of the night. Jean, Julie and Jeanfs daughter had taken over the beds in which my children, Michael, George and Anusha were sleeping. They had pushed Michael, George and Anusha onto the floor and were sleeping in their beds while my children were now sleeping on the floor.
32. Finally, I had to act, so I secretly called 911. I reported that drug addicts and prostitutes had pushed their way into our apartment, which was true. The police arrived and I opened the door. They found Jean, Julie, Jeanfs daughter and One-Legged Brenda all asleep. They woke them up and searched the place but could not find any crack. All the crack vials had been thrown down the garbage chute.
33. This was about 5:00 AM. While the police were doing this, Dayawathie called Sister Theresa Courtney and woke her up. Dayawathie did not tell Sister Threresa Courtney anything about Jean, Julie, Jeanfs Daughter and One-Legged Brenda. Instead, she complained that I was in the apartment (not mentioning that my then I had been living there for four months). The end result was that the police took away my keys to the apartment and told me to leave, which I did. Jean, Julie, Jeanfs daughter and One-Legged Brenda were still allowed to stay there. (I believe that Jimmy and Brenda Morales were not present at the time of this incident.)
34. I was at that time working for a real estate holding company at 24 Sixth Avenue in Brooklyn. Twice, my other daughter, Jessica, and her mother, Renuka, flew from Alameda California to visit us and each time they stayed with Dayawathie and my other three children at 1581 Park Avenue in New York. Dorchen Leidholdt found out about this and approached Renuka and asked for her help in getting me arrested, but Renuka refused to cooperate and instead went back to California.
35. During this time, Dayawathie was calling me 20 times a day at work asking for stuff and this was disturbing my boss as work and made his wife angry. I lost that job and I went to live with my friend from Afghanistan, Sayed Durali Shah, who lives in Far Rockaway. Dayawathie called me many times asking me to come back there, but I refused to go. One night at about 7:00 PM Dayawathie called to say that Anusha was very sick and needed to be taken to the hospital. However, Dayawathie could not take her because she needed to take care of the other three children. Therefore, Dayawathie wanted me to come to her home and either take Anusha to the hospital or else stay with the kids while Dayawathie took Anusha to the hospital.
36. I was very tired. I had been working as a taxi driver for Towne Taxi in Lawrence Long Island. I wanted to go to sleep, but in view of the emergency I got out of bed and made the two hour trip by subway from Far Rockaway to Spanish Harlem where Dayawathie lived.
37. When I walked in the door to Dayawathiefs apartment, I was surprised to find Michael, George and Anusha running around playing quite happily. Anusha did not look sick at all. Only one second later two police officers came out the bedroom and arrested me. It had all been a trap set by the police. The arresting officer was Carmen Bonilla. She had sat by Dayawathie coaching her on exactly what to say. This entire story about how Anusha was sick and needed to be taken to the hospital was a pure fabrication. Dorchen Leidholdt was involved in this, because as soon as she had arrested me Carmen Bonilla called Dorchen Leidholdt on the phone to tell her the good news. I was taken to jail.
38. They had made up a purely invented story that I had come to the apartment with my 16-year-old girlfriend and had forced our way into the apartment and had hit Dayawathiefs head against the wall. Nothing like that had ever occurred. Yes, there was such a girl, but she was 17, not 16, and we had been palling around for months but she was never my girlfriend. Dayawathie had never met her. She had never been to that apartment. Her name was Irina Novikova. She was from St. Petersberg, Russia and I was giving her lessons in shogi, or Japanese chess, of which I am a top player. She had converted to Hassidim and lived in the Machon Chana in Crown Heights, Brooklyn, but every Saturday she would sneak out to come to see me. Dayawathie had never met her but had heard about her and was jealous and thus had invented this entire story.
39. I called Irina Novikova from the jail and asked her to come to court to testify in my defense. She said she would come, but did not show up. Soon thereafter she went back to Russia and I never saw her again until she returned to America four years later,
40. When the date came for the court hearing, Dorchen Leidholdt and Dayawathie did not show up. In that event, they were supposed to release me but instead they made a new bogus charge against me and put me back in. Another six days passed. I was brought from the jail to the courthouse. I sat all day in the waiting room behind the courtroom. At 5:00 PM my court appointed lawyer came back to see me and told me that Judge Ross had gone for the day. Therefore, there would be no court hearing and I would be released as the case was dismissed. By not allowing me to come before him in open court Judge Ross had cheated me to my chance to complain that I had been held in jail for 12 days for no reason at all. I attach a copy of a letter from Dorchen Leidholdt saying that she was dropping the case because she could not prove it gby a preponderance of the evidenceh. No mention of gbeyond reasonable doubth. The letter was dated June 20 and had been delivered by hand. Nevertheless, Judge Ross had kept me in jail until June 23 even though he knew that the case was being dismissed.
41. I went to the office of the District Attorney several times demanding that Dorchen Leidholdt be criminally prosecuted for bringing this false case. However, the ADA, Eileen Chiu, said that she could do nothing because again Dayawathie had disappeared. Dorchen Leidholdt wrote a letter saying that she no longer represented Dayawathie and did not know where she was. This was another lie. Dorchen had moved Dayawathie to a facility Dorchen operated in Queens.
42. Before long, Dayawathie started calling me again. She was living in a facility operated by Sister Theresa Courtney and Dorchen Leidholdt at 166th Street and Hillside Avenue in Queens. She wanted me to come there but I refused to go. She wanted me to buy presents for the kids. Finally, I agreed to meet her at the big shopping mall on 33rd Street and Herald Square on Sixth Avenue in Manhattan. We met many times there and I would treat the kids. There were no court orders or custody orders because everything had been dissolved every time she disappeared. Still, I was afraid to come to her residence.
43. In early 1998 she got a new apartment at 40-08 12th Street, Long Island City, Queens, New York in the Queensbridge Housing Project. She did not like the place, much preferring her old apartment in Manhattan. However, she finally asked me to come live there. The deal we made was that Sister Theresa Courtney and Dorchen Leidholdt only came to see her on Saturday or Sunday and only came during the daytime because they were afraid of the black people at night. Therefore, I would never come at those times. I would maintain my own residence. If Dorchen Leidholdt or Theresa Courtney ever came at an unusual time when they were not expected, I would hide in a closet or in the stairwell on a higher floor and leave the building as soon as they entered the apartment. Dayawathie gave me keys to her apartment and to the building and I could pretty much come and go as I pleased as long as I followed those rules.
44. This has been the deal for the past seven years, from 1998 to 2005. As long as Dorchen Leidholdt and Theresa Courtney did not know about it, I could even bring friends over. My other daughters, Shamema and Jessica, have visited there. Jessica even lived there for a while. I have married and my wife Kayo and our daughter Sandra have been frequent visitors in the home. Rusudan Goletiani, who is the US Womans Chess Champion, has visited me there, as has my friend Mario Sacripante for whom I worked when I was living in Japan in 1984. I have also made friends with some of the neighbors. Thus, I have lots of witnesses who could testify that I was freely coming and going in the home for the past seven years. There has been no problem, no arrests, no custody cases, for these seven years.
45. In 1999, my other daughter, Jessica, came from California to live with me. However, she strongly preferred to stay with her half-brothers and sisters, Michael, George and Anusha, so she lived in Dayawathiefs apartment at 40-08 12th Street, Long Island City. I enrolled Jessica in school there, the same school that Michael and George were attending. However, Dorchen Leidholdt and Sister Theresa Courtney found out about this, went to the school and objected. As a result, Jessica was not allowed to attend school there. I complained to the Board of Education, to no avail. Finally I had to send Jessica back to California.
46. There has been a big problem with Surinder Singh a/k/a Kala. He was a homeless bum that Dayawathie had met while she was living in the homeless shelter at 166th Street and Hillside Avenue. He followed her to her new apartment at 40-08 12th Street. Dayawathie says that at first he was nice. However, later, he was drunk all the time. He would beat and abuse her. She would call 911. The police would come but he would run away. Sometimes he would hide on the roof of the building and come back down after the police left. Sometimes the police would even catch him in the apartment but would not arrest him even though he was obviously drunk and abusive. He was eventually arrested six times in her apartment but then the judge would let him out after just a few hours and he would come right back. Dayawathie got a dozen orders of protection against him but he just ignored them.
47. Finally, the New York City Housing Department started an eviction proceeding against Dayawathie for letting Surinder Singh into the apartment where he would cause a constant commotion. Dayawathie got Dorchen Leidholdt to defend her in this court case. Dorchen settled the case with an order in which Dayawathie agreed not to allow Surinder Singh OR Sam Sloan into her apartment, or otherwise she would forfeit the apartment. Dorchen Leidholdt added my name to the case, even though the New York City Housing Department had never heard of me. They did not even know my name because the police had never been called about me and there had never been any trouble about me.
48. This court order has made Dayawathie fearful of allowing me to stay in the apartment. I have never spent the night there since. My visits have been brief. Meanwhile, Kala has disappeared. I suspect that he was finally deported back to India.
49. It is my absence that has allowed the two drug dealers from Tioga, Pennsylvania to move in. They moved in full time in about February, 2005. Before that, they were just coming and going from Tioga to New York. I know where they are from because one time Dayawathie went to visit them in Tioga. She had me take care of the children while she was gone and gave me the number there which she told me to call in case of emergency, but she insisted that I never reveal that I had the number.
50. From all of the above, it should be obvious that Alexander Karam, Dorchen Leidholdt and Sanctuary for Families are disqualified from appearing as counsel in this case. They have their own agenda which in in conflict with the best interests of the mother and the children. Rather than prove any case they might have against me, they repeatedly uproot the children and disappear with them. They have had me arrested three times but each time they have not come to court on the court date and instead have disappeared with the children again. In 1997, Dorchen Leidholdt wrote letters saying that she no longer represents Dayawathie Rankoth and does not know where she is, but Dayawathie says that there has never been even one day when Dorchen did not know where she lives because she has been living in a facility provided by Dorchen Leidholdt. Alexander Karam is a young lawyer who just graduated from law school in 2005 and this must be one of his first cases. He works for Sanctuary for Families and obviously does not know what he is getting into.
51. Finally, 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 28th Day
of November, 2005
_______________________________
NOTARY PUBLIC
AFFIDAVIT OF SERVICE
Docket # V-11657-05
STATE OF NEW YORK, COUNTY OF QUEENS SS:
Kayo Kimura, being sworn says: I am a party to this action and I am over 18 years of age.
At 8:00 AM on November 28, 2005, I served a true copy of the attached affidavit, in the following manner:
By mailing a true copy of the same to:
Alexander Karam
Attorney for Sanctuary for Families
67 Wall Street, Suite 2211
New York NY 10006
www.sanctuaryforfamilies.com
(212) 349-6006 ext. 320
Vladimir Cadet
89-31 161st Street, Suite 505
Jamaica NY 11432
718-297-0004
________________________
Sworn to Before me this 28th
Day of November 2005
_________________________
NOTARY PUBLIC