Federal Lawsuit to Recover Kidnapped Daughter

M. ISMAIL SLOAN, individually and on behalf of his children, SHAMEMA HONZAGOOL SLOAN, MICHAEL RANKOTH SLOAN, JESSICA VITHANAGE SLOAN, GEORGE RANKOTH SLOAN and ANUSHA SLOAN, infants, and on behalf of his mother, HELEN MARJORIE SLOAN, and on behalf of VITHANAGE SANTHILATHA and RANKOTH PEDIGEDERA DAYAWATHIE and LINDA DUAVIS and HONZAGOOL,

Plaintiffs,

-against- COMPLAINT

STEPHEN R. PATTISON, EDIN BROWN, EILEEN F. LEWISON, WILLIAM CRAWFORD, MARLEE ANDERSON, CHARLES ROBERTS, SHELBY ROBERTS, JAY ROBERTS, LARRY ROBERTS, JUDGE LAWRENCE JANOW, JUDGE MICHAEL GAMBLE, JUDGE SUE H. ROE, JUDGE RICHARD S. MILLER, JUDGE DALE HARRIS, WILLIAM H. PETTY, BARBARA J. GADEN, BOONCHOO YENSABAI, JOHN L. SOBELL, FRANK DAVIDSON III, LINDA S. GROOME, KEITH REICHARD, PASTOR CHARLES ESTERLINE, PASTOR EARL CLARKSON, TEMPLE BAPTIST CHURCH AND SCHOOL, RAJA ABDUL RASHID, RAJA EHSAN AZIZ, AZIZ-UR-REHMAN, IJAZ MANSOUR QURESHI, DR. KHAWAJA MAHMOOD, FORTUNADO D. OBLENA, MASSIE G. WARE, JR., LEIGHTON HOUCK, ALMA COATES DAWSON, JOHN MILLER, CENTURION PRIVATE INVESTIGATIONS, BUSTER WALKER, JOHN, STEWART, WALKER, SOVRAN BANK, N. A., NATION'S BANK, NCNB BANK, SHARON HABERER, VITHANAGE SANTHILATHA, VIRGINIA BURKS, JAMES OLIVER, RICHARD L. GROFF, AMHERST COUNTY DEPARTMENT OF SOCIAL SERVICES, MICHAEL W. COX, OFFICER F. D. McFARLAND, OFFICER ROYER, OFFICER LARIVIERE, INVESTIGATOR GLEASON, COMMANDER BURNETTE, SANCTUARY FOR FAMILIES, KILLIS T. HOWARD, CREIGHTON W. SLOAN, W. CASSEL JACOBSON, CECIL W. TAYLOR, WILLIAM H. TUCKER, PAIGE WEEKS JOHNSON, DR. SHIELA I. MILOT, DR. MELVYN HAAS, MATTIE C. HALL HEALTH CARE CENTER, NORTHWEST AIRLINES, TRANS WORLD AIRLINES and the UNITED STATES DEPARTMENT OF STATE,

Defendants.

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M. ISMAIL SLOAN, being duly sworn, deposes and says:

1. This action is brought under the Federal Anti-Kidnapping Act, 18 U.S.C. 1201, under the Federal Hostage Taking Act, 18 U.S.C. 1203, under the Parental Kidnapping Prevention Act, 28 U.S.C. 1738A, for inducing and financing an illegal act under 18 U.S.C. 2, under the Federal Tort Claims Act, 28 U.S.C. 1346 (b), under the provisions of the Social Security Act pertaining to the rights of the elderly and the protection of residents, under the provisions of the social services acts pertaining to the welfare of children, and under the First, Fourth, Fifth, Ninth and Fourteenth Amendments to the Constitution of the United States including the First Amendment Constitutional right to freedom of religion and the First, Forth, Fifth, Ninth and Fourteenth Amendment Constitutional rights to privacy and the freedom to raise a family without outside governmental interference. This action is also brought under 42 U.S.C. 1983 for violations of the civil rights of the plaintiffs and to enjoin the actions of the state court judges, also under 42 U.S.C. 1983.

2. Jurisdiction is based upon the Klu Klux Klan Act, 42 U.S.C. 1983, Federal Question, 28 U.S.C. 1331, Federal Defendant, 28 U.S.C. 1346, Diversity of Citizenship, 28 U.S.C. 1332, Mandamus, 28 U.S.C. 1361, and pendent jurisdiction. The amount in controversy exceeds $10,000.

3. Dr. Helen Marjorie Sloan, one of the plaintiffs herein, is a moderately wealthy retired child psychiatrist, now 82 years old, who is a renowned authority on child care and child rearing. She was listed in the first edition of <+#>Who's Who in American Women<-#> . She was for 41 years employed by the Virginia State Department of Mental Health and Hygiene as Psychiatrist - Director. She is now an incarcerated prisoner, having been forcibly kidnapped by defendants to this action, including especially her youngest son, defendant Creighton W. Sloan, for the purpose of extorting money out of her.

4. Plaintiff Shamema Honzagool Sloan is an exceptionally bright and gifted child, born on October 15, 1981. Her mother is a member of the royal family of Chitral, Pakistan. According to the local legend in Pakistan, Shamema Honzagool Sloan is a direct descendant of both Ghengis Khan and Alexander the Great. Shamema has been tested to be in the highest ranges of intelligence. For example, in a test performed shortly after she was kidnapped, she was found to be reading at the eleventh grade level, even though she was only in the fourth grade.

5. Shamema Honzagool Sloan is now an incarcerated prisoner, having been kidnapped and detained by defendants named herein, including especially Charles Roberts, Shelby Roberts and Lawrence Janow. Shamema Honzagool Sloan is now a prisoner under armed guard inside the Temple Baptist Church and School, located in Madison Heights, Virginia, in Amherst County, Virginia, and is being indoctrinated into the Christian religion, against the wishes of both of her natural parents. Shamema Honzagool Sloan is not being allowed to attend school, except for the school conducted in that church. Shamema Honzagool Sloan is not allowed to have any contact with other children her age, except for children whose parents also attend that church. Shamema Honzagool Sloan has not spoken a word to an adult in the year and a half since she was kidnapped from her father, except to communicate her basic needs. Shelby Roberts, one of the kidnappers of Shamema Honzagool Sloan, has testified that, "at night, Shamema plays alone in her room with her toys."

6. At no time has any showing ever been made that M. Ismail Sloan is not a devoted father who takes good care of his children. Rather, the allegation is that these are such wonderful children that they ought to be raised in the Christian church. The kidnappers overlook the fact that these are such wonderful children because they have been well taken care of by their father and their grandmother. If these children had been taken care of by these kidnappers since birth, they would not be the wonderful children that they were up until the time that they were kidnapped.

7. In order to bring about the kidnapping and incarceration of Dr. Helen Marjorie Sloan and Shamema Honzagool Sloan, a professional kidnapper named Boonchoo Yensabai ("Boonchoo") was hired in Thailand, in August, 1990, by defendants to this action. Boonchoo was paid a total amount of $27,000 to kidnap Helen Marjorie Sloan and was paid a further additional amount of $12,000 to kidnap Shamema Honzagool Sloan, thereby receiving a total of $39,000 to perform these kidnappings.

8. In connection with receiving this $39,000 to perform these kidnappings, Boonchoo retained the services of Stephen R. Pattison ("Pattison"), a corrupt consular officer of the United States Department of State, then posted in Bangkok, Thailand. Pattison had arranged the original introduction in Thailand of Creighton W. Sloan to Boonchoo. Creighton W. Sloan was interested in having Boonchoo kidnap his mother, because Creighton W. Sloan wanted to get her money.

9. The reason that Helen Marjorie Sloan had left the United States of America in the first place four years earlier and had wound up in Thailand was that she was running away from Creighton W. Sloan, who, for his entire adult life, has been extorting money out of his mother, Creighton W. Sloan has almost never in his adult life had a job. Instead, he is a part-time stage actor and has three master's degrees, two in the field of dramatic arts, all financed by his mother.

10. Creighton W. Sloan introduced Boonchoo to W. Cassel Jacobson, who paid Boonchoo most of the $27,000 to kidnap Helen Marjorie Sloan, and to Charles Roberts, who paid Boonchoo $12,000 to kidnap Shamema Honzagool Sloan.

11. As a result of the efforts of Boonchoo, Helen Marjorie Sloan and Shamema Honzagool Sloan were kidnapped and brought to the United States. Michael Rankoth Sloan and Jessica Vithanage Sloan were also kidnapped. The defendants thereafter corruptly obtained under color of state law various interdiction orders under which these kidnapped persons were detained and not allowed to return back to their place of residence, or to leave the states to which they were taken by these kidnapers.

12. As a result of these corruptly entered court orders, Plaintiff Helen Marjorie Sloan is now being held a prisoner under physical restraint at the Mattie C. Hall Health Care Center under an ex-party detention order corruptly signed by Judge Sue H. Roe of the Aiken County, South Carolina Probate Court. Shamema Honzagool Sloan is detained by orders corruptly signed by Judges Lawrence Janow and Michael Gamble of the Amherst County Virginia Circuit and Juvenile and Domestic Relations Courts. Jessica Vithanage Sloan is detained by an order signed by Alameda County California Superior Court Judge Hoerner on the grounds of the sexual molestation of Jessica which took place after Charles Roberts had kidnapped her. Michael Rankoth Sloan, George Rankoth Sloan and Anusha Sloan are being detained in a Sanctuary for Families in New York City.

13. Thus, because of the paid kidnappings of the elderly mother and the three grandchildren, they are all separated from each other and held illegally in different states of the United States, whereas previously they were all living together under one roof in the United Arab Emirates.

14. The venue of this action is based on the fact that all of them arrived in the United States of America as a result of these kidnappings at Kennedy Airport, which is in the Eastern District of New York. In addition, plaintiff M. Ismail Sloan presently maintains a residence in Brooklyn, which is in the Eastern District of New York.

15. Prior to that time, through the first half of 1990, all of the plaintiffs named herein (with the exception of George Sloan and Anusha Sloan, who were not yet born, and Honzagool, who was in Pakistan) were living in the same house together in peace and harmony in Fujairah, United Arab Emirates, and were not bothering anybody. None of the plaintiffs herein had any desire to travel to the United States.

16. The kidnappings which thereafter took place were the culmination of efforts over a period of many years where defendants to this action had been trying to force Helen Marjorie Sloan to hand over both her money and her granddaughter. At the time that Helen Marjorie Sloan was kidnapped from her hospital bed in Bangkok, Thailand, she had a lawsuit pending against many of these same defendants to this action in which she alleged that they were trying to kidnap her and her granddaughter. The name of that case was <+#>Helen Marjorie Sloan against Judge Richard S. Miller et al<-#>. Among the other defendants to that action were Judge Janow, Sovran Bank, Leighton Houck, Creighton W. Sloan, W. Cassel Jacobson, William H. Petty, Charles Roberts and Shelby Roberts. That case had just been dismissed by Judge Ernest W. Ballou in July, 1990 and Helen Marjorie Sloan had filed a notice of appeal to the Supreme Court of Virginia. The dismissal by Judge Ballou in effect gave these defendants the green light to continue forward with their long standing efforts to kidnap Helen Marjorie Sloan.

17. As part of the general plan to kidnap Helen Marjorie Sloan and Shamema Honzagool Sloan for the purpose of extorting money out of Helen Marjorie Sloan and converting Shamema Honzagool Sloan to the Christian religion, the defendants have caused a series of arrest orders to be issued against the plaintiff M. Ismail Sloan. M. Ismail Sloan was first arrested on September 3, 1986 in New York City on the complaint of defendant Lawrence Janow, but was released a few hours later. Following the same pattern, M. Ismail Sloan was arrested in Guam on June 30, 1988, in Honolulu on June 30, 1988, in Bangkok, Thailand on September 5, 1990, in Amherst, Virginia on November 13, 1990, in New York City on November 18, 1990 and in Lynchburg, Virginia on September 4, 1991. Upon information and belief, these defendants have now obtained three additional warrants for the arrest of M. Ismail Sloan.

18. At no time has M. Ismail Sloan committed any crime at all. Rather, the criminals are the defendants to this action. All of these repeated arrests were for the purpose of kidnapping the mother and the children of M. Ismail Sloan or for the purpose of preventing M. Ismail Sloan from obtaining the recovery of his mother and children. The general plan of defendants William H. Petty, Judge Janow, Judge Gamble, Charles Roberts, Shelby Roberts and Linda S. Groome is simply to keep M. Ismail Sloan in jail until his daughter grows up and to get custody in that manner, even though they are well aware that M. Ismail Sloan has not committed any crime at all but rather that they themselves are the criminals.

19. For example, M. Ismail Sloan was arrested and detained for five hours in Bangkok, Thailand after Boonchoo had paid bribes to the police to have him arrested. During that five hours, Boonchoo succeeded in smuggling Helen Marjorie Sloan, semi-conscious and tied to a stretcher, onto a Northwest Airlines flight bound for the United States. Northwest Airlines knew that Helen Marjorie Sloan was in the process of being kidnapped, but participated in this kidnapping as a result of bribes paid by Boonchoo to the Northwest Airlines ground staff. Furthermore, defendant Stephen R. Pattison illegally issued a special new passport on an "emergency basis" to enable Helen Marjorie Sloan to be smuggled onto the Northwest Airline flight, even though Stephen R. Pattison well knew that Helen Marjorie Sloan was in the process of being kidnapped and that M. Ismail Sloan had her actual passport. All of this was made possible by the $39,000 which Boonchoo had been paid by defendants to this action to kidnap the mother and the three children of M. Ismail Sloan.

20. In a similar pattern, previously M. Ismail Sloan had been arrested in the Island of Guam by the F.B.I. on the orders of Defendant William H. Petty. The purpose of this arrest was to bring about the kidnapping of the daughter of M. Ismail Sloan, namely Shamema Honzagool Sloan. However, M. Ismail Sloan was released after only about two hours because Defendant William H. Petty had discovered that M. Ismail Sloan did not have Shamema Honzagool Sloan with him, and therefore the arrest of M. Ismail Sloan would not result in the kidnapping of Shamema Honzagool Sloan.

21. Following the same pattern, William H. Petty got M. Ismail Sloan arrested in Honolulu by the F.B.I. on June 30, 1988. Once again, M. Ismail Sloan was released only a few hours later because M. Ismail Sloan did not have Shamema Honzagool Sloan with him.

22. Continuing the same pattern, on November 13, 1990, M. Ismail Sloan was arrested on the personal order of Defendant Lawrence Janow because he was trying to recover his by then kidnapped daughter, Shamema Honzagool Sloan. He was three days in jail. During those three days, the defendants arranged to kidnap the last remaining child, Michael Rankoth Sloan, and have him taken to New York. When M. Ismail Sloan was released from jail, he discovered that Michael was missing. He went to New York to recover Michael, who had been kidnapped. He located Michael in the house of defendant Sharon Haberer, who had come to Virginia from New York to kidnap Michael. Sharon Haberer called the police and had him arrested again. M. Ismail Sloan was released from jail and eventually recovered Michael from the house of Sharon Haberer and took Michael back to Virginia. He later also recovered Jessica Vithanage Sloan, who had been kidnapped by Charles Roberts.

23. On January 25, 1991, Judge Janow found out that M. Ismail Sloan had recovered two of the three children whom he had ordered to be kidnapped, Officer Royer of the Lynchburg Police Department plus five other police officers involving three police cars were sent to the house of M. Ismail Sloan to recover the children again. Fortunately, only Jessica and her mother were present, because George was sick and had been taken to the hospital with his brother Michael, so the police were unable to get those children. The police escorted Jessica and her mother from the house of M. Ismail Sloan.

24. The next day, the mother of Jessica went to the Greyhound Bus Station and fled with her daughter in fear that Judge Janow would take away and kidnap Jessica just as he had kidnapped Shamema. They eventually reached California. Later on, M. Ismail Sloan was falsely arrested again on September 4, 1991, also for trying to recover his kidnapped daughter, Shamema. M. Ismail Sloan was falsely charged by William H. Petty, Judge Dale Harris and Judge Michael Gamble with the felony crime of interstate kidnapping, in violation of 18.2-47 of the Virginia Code, which was obviously a false charge because Shamema Honzagool Sloan had never left the back yard of his house.

25. After Jessica and her mother fled the State of Virginia in fear of Judge Janow, there was no news of their whereabouts for many months. Finally, M. Ismail Sloan received a summons dated November 7, 1991 which stated that Jessica had been abandoned by her mother in California and had been found to have been sexually molested and that if M. Ismail Sloan did not come to California to claim his daughter, Jessica would be put up for adoption. M. Ismail Sloan immediately went to California to attempt to recover his daughter. When Judge Gamble found out that M. Ismail Sloan was trying to get his daughter back, he corruptly issued yet another warrant for his arrest.

26. Judge Michael Gamble has corruptly ordered M. Ismail Sloan to be arrested for going to California to recover his twice kidnapped daughter Jessica and for going to New York to recover his twice kidnapped son Michael.

27. At the same time, Defendant Charles Roberts has been tried, convicted and sentenced to life in prison in the United Arab Emirates for the kidnapping of Shamema Honzagool Sloan. There is an international Interpol warrant outstanding for the arrest of Charles Roberts. However, Charles Roberts has not been arrested in the United States for this crime, because he is being corruptly protected by the defendants to this action, including especially defendant Judge Lawrence Janow.

28. In August, 1990, certain defendants named herein hired a professional kidnapper and extortionist named Boonchoo, who is a lawyer in Thailand, to kidnap the then 80-year-old mother and all of the three children of Plaintiff M. Ismail Sloan. Also hired and employed in this capacity was Defendant John L. Sobell, an American private detective working illegally in Thailand.

29. On September 3, 1990, Boonchoo and Sobell kidnapped Plaintiff Helen Marjorie Sloan out of her hospital bed at the Bangkok General Hospital in Bangkok, Thailand. After being held in a secret location for two nights, they boarded her in a nearly comatose condition onto Northwest Airlines Flight 28 bound for Tokyo and the United States at 6:50 A.M. on September 5th. They were able to accomplish this through bribes paid to hospital officials, police officers, immigration officers, consular officers and airline staff members. The money to do this came from the $27,000 paid by defendants to this action.

30. On October 7, 1990, the three children of the plaintiff, Shamema Honzagool Sloan, Michael Rankoth Sloan and Jessica Vithanage Sloan, were kidnapped from the home of M. Ismail Sloan in Fujairah, United Arab Emirates. However, Michael R. Sloan was abandoned the next day in Abu Dhabi, 180 miles away, and wound up in the Abu Dhabi police station, from which he was returned to his father. Shamema Honzagool Sloan and Jessica Vithanage Sloan were brought on a Trans World Airlines flight to Kennedy Airport in New York City, and from there were transported to Madison Heights, Virginia, where they were forced to stay in the home and to take up Christianity by Charles and Shelby Roberts.

31. On November 8, 1990, Ismail Sloan and Michael R. Sloan arrived on a flight to America to recover the kidnapped mother and the two kidnapped children of Ismail Sloan. Instead, on November 16, 1990, the last remaining child, Michael R. Sloan, was kidnapped in Lynchburg, Virginia by Defendant Sharon Haberer, with the assistance of Defendants Charles Roberts, Officer F. D. McFarland and Sheriff Michael W. Cox. Michael Rankoth Sloan was then taken to Far Rockaway in New York City, in the Eastern District of New York. At the time of this kidnapping, Plaintiff Ismail Sloan had been arrested and was tied up in frivolous court proceedings instituted on behalf of Charles and Shelby Roberts in the Amherst County Circuit Court. Ismail Sloan was not in a position to leave the courtroom to rescue his infant son, who, unknown to him, was in the process of being kidnapped on the orders of Sheriff Cox. Defendant Sharon Haberer knew that Ismail Sloan would be in court all day that day because Defendant Charles Roberts had informed her of this and had arranged for her to come from New York City that morning for the purposes of this kidnapping.

32. Sharon Haberer, not knowing where Michael was and never having seen him before, went on a search of the City of Lynchburg, escorted by defendant Officer F. D. McFarland. Armed only with a photograph of two-year-old Michael, they spent the day checking children in the Lynchburg area, sometimes pulling down the pants of small children to see whether they were boys or girls. When they finally recognized Michael, Sharon Haberer grabbed him and jumped into the police car. They were taken to the Greyhound Bus Station. In order to be sure that the kidnapping of Michael Sloan would be successful, Officer McFarland then waited for one and a half hours at the bus station with Sharon Haberer until the next bus came, just to make sure that M. Ismail Sloan would not be able to get back Michael, even if he got out of jail on time.

33. The purpose of all of these kidnappings is and has been to seize control of the financial assets and income of Helen Marjorie Sloan, who has a considerable net worth relative to Lynchburg and a monthly income of more than $4,000, to take the three children for illegal adoption, and to convert the children to Christianity.

34. These kidnappings cost the defendants a total estimated amount in excess of $60,000, including the $39,000 in fees paid to Defendant Boonchoo. There were also transportation expenses. The defendants have provided an itemized list of some of these expenses to Judge Sue H. Roe of the Aiken County, South Carolina Probate Court in an effort to obtain reimbursement for these kidnapping expenses from the estate of Helen Marjorie Sloan. The defendants have also applied to the courts to sell the house of Helen Marjorie Sloan. In other words, Plaintiff Helen Marjorie Sloan has been forced to finance her own kidnapping and the kidnappings of her own grandchildren, plus her own incarceration.

35. The plaintiffs to this action seek the release from custody of Helen Marjorie Sloan and the release from custody of Shamema Honzagool Sloan, both of whom have been detained by corruptly entered court orders under color of state law. Helen Marjorie Sloan wishes to be allowed to return to her own home, which is located at 917 Old Trent's Ferry Road in Lynchburg, Virginia. Meanwhile, the defendants are trying to sell that house and get the money in order to prevent Helen Marjorie Sloan from returning there.

36. The plaintiffs seek the release from custody of Shamema Honzagool Sloan, who is being detained under armed guard inside the Temple Baptist Church by Defendants Charles Roberts, Shelby Roberts, Pastor Charles Esterline, Pastor Earl Clarkson and Keith Reichard on the basis of orders corruptly entered by Judge Lawrence Janow and Judge Michael Gamble.

37. Plaintiffs seek an order of injunction against the corrupt state officials named as defendants to this action, prohibiting these state officers from taking any further measures to prevent the natural reunification of this family. Plaintiffs also demand an injunction prohibiting the defendants from repeatedly arresting M. Ismail Sloan for his natural and perfectly lawful efforts to get his family back together again.

38. A further purpose of this action is to force the defendants to return to the United States of America Honzagool, who is the mother of Shamema Honzagool Sloan. Honzagool has been detained for the last ten years in Pakistan. The plaintiffs also incidentally seek one hundred million dollars in damages.

THE PARTIES

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39. All of the plaintiffs named herein were legal residents of Fujairah in the United Arab Emirates ("UAE"), with the exception of Honzagool, who was, at all times, in Pakistan, and George and Anusha Sloan, who were not yet born. However, because of the aforementioned kidnappings, all of the plaintiffs are now present in the United States, with the exception of Linda Duavis and Honzagool. Their mailing address here for the purposes of this case is 50 Broad St., Suite 2266, New York, NY 10004. However, their actual whereabouts are scattered about due to the kidnappings by the defendants.

40. The reason that plaintiffs Helen Marjorie Sloan, Shamema Honzagool Sloan and M. Ismail Sloan took up residence in the UAE in the first place is that they were forced to flee the United States in 1986 because of the efforts of Creighton W. Sloan to kidnap Helen Marjorie Sloan and the efforts of Lawrence Janow and Charles Roberts to kidnap Shamema Honzagool Sloan. M. Ismail Sloan, Shamema Honzagool Sloan and Helen Marjorie Sloan remained in the UAE for four years and during that entire four years, Creighton W. Sloan was engaged in an ongoing effort to kidnap Helen Marjorie Sloan, whereas Charles Roberts and Judge Janow spent the entire four years trying to arrange the kidnapping of Shamema Honzagool Sloan.

41. Helen Marjorie Sloan wants to be allowed to return to her own home at 917 Old Trent's Ferry Road, Lynchburg, VA 24503, but is being prevented by the defendants from doing so. She was repeatedly kidnapped out of that house in 1984 by defendant Creighton W. Sloan. Creighton W. Sloan kidnapped his mother on April 4, 1984, and took her to North Carolina just a few hours after she had appeared in court before Judge Dale Harris in an unsuccessful application for the custody of Shamema. Creighton W. Sloan was already allied with Charles Roberts and he did not want for his mother to have anything to do with Shamema and kidnapped her for that reason. Helen Marjorie Sloan thereafter gave him some money and he released her and allowed her to return to her job as a staff doctor in a hospital. On July 1, 1984, Creighton W. Sloan kidnapped her again, this time out of her hospital office. This pattern continued and, as a result, she finally fled the USA altogether in 1986. She is now a prisoner in South Carolina. Thus, she has been prohibited from occupying her own home for the past eight years, all because of the nefarious deeds of the defendants.

42. This action is brought on behalf of Helen Marjorie Sloan pursuant to a general power of attorney which Helen Marjorie Sloan gave to Ismail Sloan on February 2, 1987 which authorized him to institute and prosecute legal proceedings and all other matters in her behalf. This power of attorney is recorded in the Lynchburg Circuit Court.

43. M. Ismail Sloan ("Ismail Sloan") is a 47 year old author and securities dealer. His original name is Samuel H. Sloan. He still uses both names interchangeably. He grew up in Lynchburg, Virginia. In 1977, he converted to the Muslim religion and since 1978 he has lived a majority of his time outside of the United States, mostly in Muslim countries.

44. In February, 1980, Ismail Sloan married Honzagool, a young woman from a destitute family in the high mountain area of Chitral in Northern Pakistan, twelve miles by foot from Afghanistan. In spite of her poverty, Honzagool happened to be a member of the royal family of her region of Pakistan. This marriage produced a child, Shamema Honzagool Sloan, who was born in New York City on October 15, 1981. Because of this marriage plus her great beauty and her royal origins, Honzagool became one of the most famous personalities in Pakistan, with hundreds of newspaper articles written about her and her daughter, Shamema. The names of Honzagool and Shamema became virtually household words in Pakistan. Even the then President of Pakistan, General Zia-ul-Haq, took an interest in Honzagool and granted her a personal audience, most likely because of her reputation for great beauty. Because of this prominence, Honzagool and Shamema had their photographs published on the front page of the New York Daily News on March 26, 1982.

45. Honzagool is a United States green card holder as the result of her marriage to M. Ismail Sloan. However, she left the United States on August 28, 1982 on what she believed would be a two week visit to her mother's house in Pakistan. She was thereafter detained by defendants Aziz-ur-Rehman, Raja Ehsan Aziz, Raja Abdul Rashid and Dr. Khawaja Mahmood. Since that time, for the past ten years, Honzagool has not been allowed to return to the United States.

46. Plaintiff Michael Rankoth Sloan was born in Oakland, California on June 18, 1988. His mother is Plaintiff Rankoth Pedigedera Dayawathie, who was born on February 1, 1969 in Kandy, Sri Lanka. Almost immediately after his birth, Michael was taken by his parents to live in Abu Dhabi in the United Arab Emirates. Since that time, two more children have been born to them. George Rankoth Sloan was born on April 28, 1990 in Queens, New York. Anusha Sloan was born on November 29, 1991 in New York, New York. Their present address is c/o Sanctuary for Families, 308 West 46th Street, Third floor, New York, NY 10108.

47. Plaintiff Jessica Vithanage Sloan was born on September 14, 1988, in Oakland, California. Like, Michael, Jessica was taken by her parents almost immediately after birth to live in the United Arab Emirates. The mother of Jessica is Vithanage Santhilatha, also known as "Renuka" or "Shanti". Shanti was born on December 18, 1968 in Kalutara, Sri Lanka.

48. Helen Marjorie Sloan was born in Spalding, Iowa on March 17, 1910. She is the grandmother of these three children. She graduated from the University of Iowa Medical School and took her residency in pediatrics and psychiatry. She practiced as a child psychiatrist for many years, including 23 years in Lynchburg, Virginia. She ended her career as a staff doctor at Western State Hospital in Staunton, Virginia, retiring in 1984. Because of her long years of service and her frugal life style, she has an exceptionally high retirement income, amounting to more than $4000 monthly. Because of her secure financial position, she has become the target of various individuals named as defendants herein who want to get control of her so that they can control her money. For this reason, in 1986, she fled the United States altogether and went to live in the United Arab Emirates.

49. Honzagool, the mother of Shamema, was awarded custody of Shamema in May, 1982 in a highly publicized court case featured on the nightly television news in New York City. Custody was awarded by Judge Mercorella of the Bronx Supreme Court on May 2, 1982. However, almost immediately thereafter, Honzagool returned to her native Pakistan on August 28, 1982. The father, Ismail Sloan, was then left to raise up Shamema by himself. Shamema was only ten months old at that time. For this reason, he hired the wife of Larry Roberts, and later the mother, Shelby Roberts, as full time baby sitters to care for Shamema.

50. Starting in November, 1982, Ismail Sloan received death threats from the "Black Muslim Underground Militant Organization", which demanded that the child be handed over. These death threats were actually written by Ijaz Mansour Qureshi, a defendant to this action. For this reason, Ismail Sloan decided to keep the baby hidden on Amelon Road, in Madison Heights, Virginia, because of the virtual impossibility of anybody finding her there. The reason for this was the constant and very real danger that Shamema might be kidnapped either by the Black Muslims in New York or by the Pakistanis, both groups having seen her picture on television and in the newspapers and having expressed an interest in having Shamema. Thereafter, Ismail Sloan and later his mother, Helen Marjorie Sloan, paid Shelby Roberts a regular salary of $110 per week to care for Shamema. Over a period of the next four years, Shelby Roberts received more than $20,000 through this arrangement.

51. Charles Roberts, Shelby Roberts, Jay Roberts and Larry Roberts reside at 420 Amelon Road, Madison Heights, Virginia 24572. By 1986, Shelby Roberts had developed an attachment to the child to such an extent that she wanted to raise the child in her own religion, which is the Jerry Falwell version of Christianity, rather than the religion of both of the parents of Shamema, which is Islam. Shelby Roberts also wanted to enroll Shamema in kindergarten one in the Temple Baptist School and to change the name of Shamema Sloan to Shamema Roberts. Charles Esterline, the pastor of the Temple Baptist Church had already performed a religious ceremony in 1986 converting Shamema to the Christian religion, without the knowledge or the permission of her parents. For these and other reasons, Ismail Sloan abruptly terminated the services of Shelby Roberts as a baby-sitter and took the child out of state on August 25, 1986.

52. Two days later, Shelby Roberts, along with her husband, Charles Roberts, sued for the custody of Shamema. Their attorney in this frivolous suit was Defendant Frank Davidson III, who specializes in adoptions. He later transferred the case to defendant Linda S. Groome. The address of Frank Davidson III is Sovran Bank Building, 901 Main St., Lynchburg, VA 24504. The address of Linda S. Groome is Courtside Athletic Center, Fenwick Drive, Lynchburg, VA 24502.

53. Defendant Judge Lawrence Janow is a Judge of the Amherst County Juvenile and Domestic Relations Court. Judge Janow has been on a personal campaign for the last four years to take away all of the children of the plaintiff, without any legal grounds or reasons for doing so, in clear absence of all jurisdiction.

54. Defendant Boonchoo Yensabai in a lawyer in Bangkok, Thailand with a financial interest in various houses of prostitution, who is involved in the kidnapping of young women for the purpose of turning them into prostitutes, this being a common practice in Thailand. Another common practice in Thailand is the kidnapping and selling of babies, for the purpose of adoption in other countries such as Malaysia. Boonchoo is one of the most notorious personalities in Thailand. His name is frequently in the newspapers due to his involvement in various illegal activities, including land deals involving the swindling of landless peasants. Boonchoo was hired in this case to kidnap the mother and the children of the plaintiff. He also put one of the plaintiffs in this case, Vithanage Santhilatha, into a house of prostitution, known in the local language as a "ladies home", for one night in Bangkok. The address of Boonchoo is 946 Dusit Thani Building, Rama IV Road, Bangkok, Thailand.

55. Defendant John L. Sobell is an American private detective living in Thailand. He has no fixed address, but can be contacted through the address of Boonchoo or through Defendant Stephen R. Pattison.

56. Defendants Stephen R. Pattison, Edin Brown, Eileen F. Lewison, and William Crawford are consular officers of the United States Department of State. Defendant Marlee Anderson is employed by the Department of State in Emergency Citizens Services. Defendant Stephen R. Pattison is posted in the U. S. Embassy in Bangkok, Thailand. Defendant Edin Brown was, at the time pertinent to this case, posted in the U. S. Embassy in Colombo, Sri Lanka. Defendant Eileen F. Lewison was posted in the U.S. Consulate in Dubai, United Arab Emirates. All of them have given unauthorized information about the whereabouts of the plaintiffs to Defendant Charles Roberts, which Charles Roberts and his agents then used to kidnap the children of the plaintiff.

57. Defendant Stephen R. Pattison personally assisted in the kidnapping of Helen Marjorie Sloan and attempted to kidnap Shamema Sloan, Michael Sloan and Jessica Sloan as well. Defendant Stephen R. Pattison gave a green light to these kidnappings. Pattison illegally caused Plaintiff Ismail Sloan and his family to be stranded in Thailand for two months in order to have enough time to set up and arrange these kidnappings. Pattison also illegally issued to Boonchoo a replacement passport in the name of Helen Marjorie Sloan in order to enable Boonchoo to smuggle Helen Marjorie Sloan out of Thailand against her will. Pattison further attempted unsuccessfully to have the three infant children of the plaintiff arrested in Thailand.

58. Due to the conspiracy between Boonchoo and Pattison, Ismail Sloan was arrested on September 5, 1990 on the baseless charge that Ismail Sloan had slandered Boonchoo's character by reporting to the Bangkok police that Boonchoo had kidnapped his mother. Ismail Sloan was held in jail for five hours, long enough for his kidnapped mother to be smuggled out of Thailand and for a search to be conducted as to the whereabouts of his three children for the purpose of kidnapping them as well. Not only did Pattison fail to perform his consular duty to help Ismail Sloan get out of jail, but he contrived to keep Ismail Sloan in jail when he otherwise would not have been there, solely for the sake of bringing about the kidnappings and extradition of his mother and children.

59. Defendant Edin Brown is a consular officer of the United States Department of State then posted in Colombo, Sri Lanka. Edin Brown illegally placed or attempted to place a stop on the passport of M. Ismail Sloan for reasons of personal animosity towards him. The result of this was that M. Ismail Sloan was initially stranded for 19 days in Bangkok because he could not get a new passport issued. During that 19 days, the mother, plaintiff Helen Marjorie Sloan, became ill with a virus and eventually was kidnapped. Therefore, it was because of the illegal acts of Edin Brown in asking that a stop be placed on the passport of M. Ismail Sloan which started a chain of events leading to the kidnapping of Helen Marjorie Sloan and Shamema Honzagool Sloan.

60. Defendant William Crawford is an officer in Overseas Citizens Services in the State Department in Washington. He also gave information which assisted Charles Roberts in the kidnapping of the children. Marlee Anderson helped facilitate the kidnapping of Helen Marjorie Sloan from her hospital bed in Bangkok. The address of all of them is: The State Department, Washington, D. C. 20520.

61. Defendant Massie G. Ware, Jr. is an officer of Defendant Sovran Bank, N.A. in Lynchburg, Virginia. These defendants have squeezed the 82-year-old grandmother, by refusing to allow her to have access to any of the estimated $160,000 in her Sovran Bank account, even when these funds were necessary to pay the hospital bills to save her life. By this criminal refusal to give the plaintiff her own money, these defendants facilitated her ultimate kidnapping by Boonchoo. Defendant Judge Richard S. Miller is a judge of the Lynchburg Circuit Court who, acting in a clear absence of all jurisdiction, corruptly facilitated the seizure of the assets of Helen Marjorie Sloan and gave tacit approval to her being kidnapped.

62. Defendant Sharon Haberer resides at 1105 Neilson Street, Far Rockaway, New York 11691. She is a co-religionist with defendant Charles Roberts. After M. Ismail Sloan had been arrested in Amherst, Virginia on November 13, 1990, Charles Roberts contacted Sharon Haberer and had her come down to Virginia and kidnap Michael Sloan.

63. Defendant Virginia Burks was at times pertinent to this complaint the Director of the Amherst County Department of Social Services in Amherst, Virginia 24521. Defendant Richard L. Groff is a case worker in the Amherst County Department of Social Services. Almost immediately after the kidnapping of these children and their arrival in Amherst County, Virginia Burks resigned as director. Her replacement was Defendant James Oliver.

64. Defendant Michael W. Cox is the Sheriff of Amherst County, Virginia. Defendants Officer F. D. McFarland, Officer Royer, Officer Lariviere, Commander Burnette and Investigator Gleason are all officers in the Lynchburg Police Department. Their address is 901 Court Street, Lynchburg, VA 24504.

65. Defendants Killis T. Howard and Leighton Houck are Lynchburg lawyers who were involved in the kidnapping of Plaintiff Helen Marjorie Sloan from her hospital bed in Bangkok, Thailand and in the illegal seizure of her assets. The address of Killis T. Howard is 712 Court Street, Lynchburg, VA 24504. The address of Leighton Houck is 2306 Atherholt Road, Lynchburg, VA 24502.

66. Defendant Creighton W. Sloan, 45, is the son of Helen Marjorie Sloan and the brother of Ismail Sloan. His address is 102 Indian Creek Trail, Aiken, South Carolina 29803.

67. Defendant W. Cassel Jacobson is the 79-year-old brother of Helen Marjorie Sloan. He resides at 1101 Orchard Way, Silver Spring, Maryland 20904. Both Creighton W. Sloan and W. Cassel Jacobson have been involved in extensive litigation against Helen Marjorie Sloan since 1986 in an effort to seize control of her assets. They have also been cooperating with Charles and Shelby Roberts in their efforts to kidnap the children of M. Ismail Sloan. They offered to provide $5,000 to Charles and Shelby Roberts for use in kidnapping the three children of M. Ismail Sloan, and got that money from the bank account of Helen Marjorie Sloan.

68. Defendant Northwest Airlines is the airline which transported Helen Marjorie Sloan forcibly against her will from Bangkok, Thailand to the United States to enable defendants Creighton W. Sloan, W. Cassel Jacobson, Killis T. Howard and other defendants to seize control of the assets and income of Helen Marjorie Sloan. Prior to boarding her on the aircraft, the Northwest representative in Bangkok was shown by M. Ismail Sloan an interdiction order prohibiting the removal of Helen Marjorie Sloan from Thailand on the ground that she had been kidnapped. In spite of seeing this order, Northwest Airlines boarded her on the aircraft anyway.

69. Defendant Lawrence Janow is a judge of the Amherst County Juvenile and Domestic Relations Court. Defendant Michael Gamble is a judge of the Amherst County Circuit Court. Defendant Sue H. Roe is a judge of the Aiken County Probate Court. Defendant Richard S. Miller is a judge of the Lynchburg Circuit Court. Defendant Dale Harris is a judge of the Lynchburg Family Court.

70. Defendant Lawrence Janow is the judge who masterminded this entire scheme to kidnap the children, starting in 1986. The sole reason for this was the personal hostility which Judge Janow feels towards plaintiff M. Ismail Sloan.

71. Defendant William H. Petty is the Lynchburg Commonwealth Attorney. Defendant Petty has repeatedly issued orders for the arrest of plaintiff M. Ismail Sloan, even though the acts alleged occurred outside of his jurisdiction. For example, in August, 1986, Charles Roberts applied to the Amherst County Commonwealth Attorney for an order for the arrest of M. Ismail Sloan. This request was denied. Then Charles Roberts went to the Lynchburg Commonwealth Attorney and asked for an arrest warrant there. William H. Petty issued the arrest warrant, even though all of the acts complained of by Charles Roberts occurred in Amherst County, which was outside of the jurisdiction of Defendant Petty.

72. All of these arrest warrants have been entirely for the purpose of assisting Charles Roberts in obtaining custody of Shamema. The defendants are well aware that M. Ismail Sloan is not guilty of any crime. However, they keep issuing these arrest warrants solely for the purpose of stealing the money of Helen Marjorie Sloan and kidnapping the children of M. Ismail Sloan.

73. The reason that they keep doing this is that plaintiff M. Ismail Sloan has a proven capability of producing highly intelligent children, which the defendants are incapable of producing themselves. Therefore, they want to kidnap the children of M. Ismail Sloan in order to make up for their own inadequacies in producing intelligent, gifted and well taken care of children. In addition, they want to convert all of these children to the Christian religion.

74. The address of defendants Keith Reichard, Pastor Charles Esterline, and Pastor Earl Clarkson is c/o Temple Baptist Church and School, Route 29N, Madison Heights, VA 24572.

75. Defendant Ijaz Mansour Qureshi is a nuclear physicist employed in the nuclear weapons development program of the Government of Pakistan. He first became involved in this case in 1982 when he was still a graduate student of physics at the University of Toronto. He had read about Honzagool in the newspapers and about the fact that she was considered to be one of the most beautiful women in Pakistan. He decided that he wanted to marry her, but the only fly in the ointment was that she was already married to M. Ismail Sloan. He therefore started writing death threats to M. Ismail Sloan under the name "Black Muslim Underground Militant Organization", while also writing marriage proposals to Honzagool.

76. Ijaz Mansour Qureshi currently resides in the Nuclear Weapons Development Facility in Muree, Pakistan.

77. Defendant Dr. Khawaja Mahmood is a millionaire Pakistani businessman with homes in both Islamabad, Pakistan and Howard Beach, Queens, New York. He became involved in this case because he wanted for his son to marry Honzagool. For that reason, he put out a contract on the life of M. Ismail Sloan. His mailing address is 100 Harley Street, Rawalpindi, Pakistan.

78. Defendant Aziz-ur-Rehman is a cousin of Honzagool. He arranged the marriage of Honzagool to M. Ismail Sloan in 1980. A condition of the marriage contract was that M. Ismail Sloan would provide a visa for Aziz-ur-Rehman to come to America, which M. Ismail Sloan did. However, Aziz-ur-Rehman overstayed his visa, was twice arrested by the INS and was eventually deported to Pakistan on July 21, 1982. Thereafter, Aziz-ur-Rehman filed a case in the courts of Chitral, Pakistan, acting under a power of attorney, in which he demanded a divorce by Honzagool from M. Ismail Sloan. The judge on the case, Mian Hafiz-ur-Rehman, who was the EAC of Chitral, refused to grant a divorce decree. For this reason, in 1984, Aziz-ur-Rehman contacted two brothers who were relatives of Honzagool and who lived in the village of Singur, which is near the Chitral Power Station. These two brothers murdered the judge with a hatchet and threw his body into the Chitral River. After that, Aziz-ur-Rehman, without much difficulty, found a more compliant judge in the Rawalpindi Family Court in Rawalpindi, Pakistan. Honzagool was brought all the way from Chitral to Rawalpindi and, on the same day, the judge granted a divorce decree without notice to M. Ismail Sloan. Honzagool was then married to defendant Raja Abdul Rashid, as a second wife, also on the same day, in return for a large sum of money being paid by Raja Abdul Rashid to Aziz-ur-Rehman, in accordance with the tribal customs.

79. Since that time, Raja Abdul Rashid and his brother, Raja Ehsan Aziz, have detained Honzagool in Pakistan. They have established a not-for-profit corporation in Teaneck, New Jersey called the Honzagool Defense Committee. They conduct mailings and have raised a large sum of money in this manner. Essential to the success of this scheme is to keep Honzagool in Pakistan, because if she ever returns to the USA and is able to reclaim her daughter, there will no longer be any need for anyone to donate money to the Honzagool Defense Committee.

80. These activities have made Aziz-ur-Rehman one of the richest men in Chitral, whereas previously he was unable to feed his family. He has constructed a school on his ancestral lands with the money he obtained from the Honzagool case. His address is c/o Drosh Public School, Drosh, Chitral, Pakistan. The address of Raja Abdul Rashid and Raja Ehsan Aziz is House No. 161, Street 60, G 9/4, Islamabad, Pakistan.

81. Defendant Barbara J. Gaden is an Assistant Attorney General for the State of Virginia. Her address is Supreme Court Building, 101 North 8th Street, Richmond, VA 23219.

82. Defendant Buster Walker is the President of John, Stewart, Walker, which is located at 3211 Old Forest Road, Lynchburg, VA 24502. Buster Walker and John Stewart Walker have circulated thousands of wanted posters featuring the photographs of M. Ismail Sloan, Shamema Honzagool Sloan and Helen Marjorie Sloan in their effort to capture and kidnap Helen Marjorie Sloan and Shamema Honzagool Sloan.

83. Defendant Cecil W. Taylor is a lawyer who is presently trying to sell the house of Helen Marjorie Sloan against the wishes of Helen Marjorie Sloan. His address is 1003 Church St., P. O. Box 1017, Lynchburg, VA 24505.

84. Defendants William H. Tucker and Paige Weeks Johnson are lawyers in Aiken, South Carolina. The address of William H. Tucker is 101 Park St., Aiken, SC 29801. The address of Paige Weeks Johnson is 117 Pendleton St., NW, Aiken, SC 29801. They have been trying to gain control of the assets of Helen Marjorie Sloan against the wishes of Helen Marjorie Sloan.

85. Defendants Dr. Melvyn Haas and Dr. Shiela Milot are doctors in Aiken, South Carolina. The address of Dr. Melvyn Haas is 210 University Parkway NW, Aiken, SC 29801. The address of Dr. Shiela I. Milot is 1518 Two Notch Road, Aiken, SC 29801. These doctors have signed interdiction orders without taking the trouble to give a proper diagnosis of Helen Marjorie Sloan. These orders provide that Plaintiff Helen Marjorie Sloan is not to be allowed to escape from the facility where she is being detained. Their sole reason for doing this is to assist in the nefarious scheme by defendant Creighton W. Sloan to steal all of the assets of Helen Marjorie Sloan.

86. Helen Marjorie Sloan is possessed of the full power of her mind and body and there is nothing wrong with her, considering her age of 82. Helen Marjorie Sloan is far more capable than is Creighton W. Sloan of handling her finances. However, she is unsure of her whereabouts, in view of the fact that she has been kidnapped and taken by force to a place where she has never been before.

87. Defendant Mattie C. Hall Health Care Center is a nursing facility located at 830 Laurens St., Aiken, SC 29801. After Plaintiff Helen Marjorie Sloan was kidnapped from her hospital bed in Bangkok, Thailand, she was taken to a nursing facility near Silver Spring, Maryland, from which she promptly tried to escape. That nursing home finally kicked her out for repeatedly trying to break out and for fighting with and beating up the nurses. She was then transferred to another nursing home, with the same result. On November 11, 1990, the same day that M. Ismail Sloan arrived in Virginia to recover his kidnapped mother and two kidnapped children, Helen Marjorie Sloan was transferred by defendant W. Cassel Jacobson to South Carolina. Again, in South Carolina, Helen Marjorie Sloan repeatedly tried to escape. Finally, they found the Mattie C. Health Care Center. Mattie C. Health Care Center has a secure facility with electronically controlled doors resembling that of a prison which makes it impossible to escape from there. Every day, Helen Marjorie Sloan walks around this facility testing the doors and windows, trying to figure out a way to break out. Helen Marjorie Sloan is still physically strong and it requires the combined efforts of two or three nurses to physically overpower Helen Marjorie Sloan.

88. The reason that Helen Marjorie Sloan cannot escape is that she in locked into such a secure facility that there is no way for anybody to break out of there and, secondly, Judge Sue H. Roe has threatened M. Ismail Sloan with arrest should he come to South Carolina to try to rescue his kidnapped mother. Judge Sue H. Roe has done this even through she well knows that Helen Marjorie Sloan never resided in South Carolina prior to being kidnapped. The reason for this is that Judge Sue H. Roe wants to secure a substantial inheritance tax for the coffers of the state. Judge Sue H. Roe has decreed that Helen Marjorie Sloan will never in her life be allowed to leave the State of South Carolina but rather that she must be kept there and that all of her assets must be transferred there and deposited with defendant NCNB Bank, so that the state can get its tax.

89. Defendant Nation's Bank is a successor to Defendants Sovran Bank and NCNB Bank. In December, 1986, plaintiff Helen Marjorie Sloan decided that her funds were being mismanaged by defendant Massie G. Ware, who was a trust officer of Sovran Bank, and therefore instructed the bank to transfer all of her funds to her checking account so that she could manage them herself. However, due to the sagging financial condition of Sovran Bank, they were reluctant to move the money. Therefore, Sovran Bank applied to defendant Judge Richard S. Miller on an ex-party basis, who corruptly entered an order freezing the Sovran Bank account, to prevent Helen Marjorie Sloan from having access to her money. That money is still frozen to this day. Plaintiff Helen Marjorie Sloan has never been given an opportunity to unfreeze her account. In addition, Defendant Massie G. Ware confiscated the funds in the personal Sovran Bank checking account of M. Ismail Sloan, who had about $3500 in his account.

90. This freeze was placed on an ex-party basis, without any notice to Helen Marjorie Sloan, who was at all times in the United Arab Emirates. Helen Marjorie Sloan then wrote to Judge Miller demanding that the freeze be lifted. Judge Miller responded by saying that if Helen Marjorie Sloan wanted her money back, she would have to travel to Virginia and personally appear before him. Helen Marjorie Sloan responded that she was not willing to do that because she was sure that if she did that her son, Creighton W. Sloan. was going to kidnap her, just as he had done several times in the past and, secondly, it was clear that Judge Miller had no jurisdiction to freeze her bank account, so she saw no reason to submit to his jurisdictional by traveling to Virginia. This situation remained in deadlock and eventually led to Helen Marjorie Sloan being kidnapped four years later.

91. The result of this situation is that all of the funds of Helen Marjorie Sloan have been frozen into Sovran Bank and NCNB Bank, which recently merged to become Nation's Bank. Nation's Bank is in weak financial condition due to bad commercial real estate loans and is probably insolvent. However, the funds of Helen Marjorie Sloan cannot be withdrawn from this bankrupt bank, because of orders corruptly entered by Judge Richard S. Miller and Judge Sue H. Roe.

92. Defendant Alma Coates Dawson is a close friend of Charles Roberts and Shelby Roberts and was for many years the personal chauffeur of Leroy B. Sloan, the father of M. Ismail Sloan. Leroy B. Sloan was a lawyer and a tax auditor for the IRS. Alma Coates Dawson claims that she married Leroy B. Sloan in the emergency room of the Lynchburg General Hospital 19 days before he died, and has sued M. Ismail Sloan for her claimed "widow's share" of his estate. Her attorney on the case was Michael Gamble, who later became the judge on this case. Alma Coates Dawson hired defendant John Miller, a private detective with defendant Centurion Private Investigations, to investigate this case.

93. Defendant Centurion Private Investigations is a private detective agency which advertises its services in the local news media as a kidnapper of children. Their services were sought out by Charles and Shelby Roberts, because they wanted to have Shamema kidnapped and brought to America. Thereafter, in 1988, John Miller of Centurion Private Investigations approached Judge Janow with an offer of a bribe for information and assistance in connection with the Shamema Honzagool case. Judge Janow claims that he refused the offer of a bribe. When M. Ismail Sloan returned to Lynchburg after his daughter Shamema had been kidnapped and brought there, John Miller along with Larry Roberts and Jay Roberts, sons of Charles Roberts, often followed M. Ismail Sloan around in his car.

94. The address of Honzagool is c/o Zar Khan, P.O. Jinjoret, Drosh, Chitral, Pakistan. The address of Fortunado D. Oblena is Philippine Embassy, P. O. Box 3215, Abu Dhabi, United Arab Emirates. The address of Vithanage Santhilatha is 21159 Ashfield Ave., Castro Valley, Calif. 94546. The last known address of Linda Duavis is c/o Philippine Embassy, P. O. Box 3215, Abu Dhabi, United Arab Emirates. The address of Judge Lawrence Janow is Amherst County J & D Court, Amherst, VA 24521. The address of Judge Michael Gamble is Amherst County Circuit Court, Amherst, VA 24521. The address of Judge Sue H. Roe is Aiken County Probate Court., 100 Park St., Aiken, SC 29801. The address of Judge Richard S. Miller is Lynchburg Circuit Court, 900 Court St., Lynchburg, VA 24504. The address of Judge Dale Harris is Lynchburg Family Court, 1001 Church St., Lynchburg, VA 24504. The address of William H. Petty is Lynchburg Commonwealth Attorney, 901 Church St., Lynchburg, VA 24505. The last known address of Alma Coates Dawson is c/o Don Pendleton, 200 Main St., Amherst, VA 24521. The address of Massie G. Ware, Jr. is Sovran Bank, 901 Main St., Lynchburg, VA 24504. The address of Buster Walker is John Stewart Walker, 3211 Old Forest Road, Lynchburg, VA 24502. The address of James Oliver and Richard L. Groff is Amherst County Department of Social Services, Amherst, VA 24521. The address of Michael W. Cox is Sheriff's Office, Amherst, VA 24521. The address of Nation's Bank is 222 Mitchell Street, Atlanta, Georgia. The address of Northwest Airlines is Minneapolis International Airport, Minneapolis, Minnesota.

COUNT I

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95. The plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 94 of this complaint.

96. The action under this count is a habeas corpus petition to obtain recovery of the kidnapped mother and the kidnapped children of plaintiff Ismail Sloan. One of the questions presented by this case is whether it is legally permissible to kidnap infant children from a foreign country, bring them to the United States, and then sue for their custody in the United States. This action arises in part because of the abduction on October 7, 1990 by Charles Roberts and other defendants of three children named as plaintiffs, as a result of which two of these children were brought to America on October 9, the other having been abandoned in Abu Dhabi. Charles and Shelby Roberts and Frank Davidson III thereafter filed a custody petition for the custody of Shamema, one of those kidnapped children, in the Amherst County Juvenile and Domestic Relations Court on October 19, 1990 before Defendant Judge Janow. The plaintiffs seek an order enjoining any Virginia judge from proceeding in that case, on the grounds, among others, that Virginia has no jurisdiction in a case involving children who were kidnapped from a foreign country and who are otherwise not resident of the State of Virginia, especially when the natural mother still has legal custody in Bronx, New York.

97. The plaintiffs demand, under this count, an order enjoining all of the state court proceedings related to this suit, plus a writ of habeas corpus requiring the production of Helen Marjorie Sloan, Shamema Honzagool Sloan, Michael Rankoth Sloan, Jessica Vithanage Sloan, George Rankoth Sloan and Anusha Sloan in this court. The plaintiffs further demand an order placing the assets and income of Helen Marjorie Sloan under the temporary jurisdiction of this court, to stop the defendants herein from further looting of the assets of Helen Marjorie Sloan. The plaintiffs further demand an order enjoining the defendants from selling or attempting to sell the house of Helen Marjorie Sloan at 917 Old Trent's Ferry Road in Lynchburg, Virginia on the grounds that Helen Marjorie Sloan has repeatedly stated that she wants to live out the remaining years of her life in that house. The plaintiffs seek an order restoring the children to their rightful father, Ismail Sloan, and allowing them to return to their situation which existed prior to these kidnappings. Plaintiffs seek an order allowing Helen Marjorie Sloan to return to her own home with her own grandchildren, as she desires to do. Plaintiffs seek an order requiring the defendants to restore to the bank account of Helen Marjorie Sloan all funds removed from that bank since the date of her kidnapping. Plaintiffs seek an order requiring Defendant Sovran Bank to provide to them or to file with this court all of the recent periodic bank statements of Helen Marjorie Sloan, since Sovran Bank (now Nation's Bank) is still persistently refusing to provide these bank statements. Finally, plaintiffs seek an order enjoining all of the defendants from further harassment of the plaintiffs herein, so that the plaintiffs will be allowed to conduct their own life styles, without further interference from these defendants. Plaintiffs also seek one hundred million dollars in damages.

FACTS

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98. In September, 1983, M. Ismail Sloan filed a petition before defendant Judge Dale Harris of the Lynchburg Family Court for the custody of Shamema. However, Judge Harris refused to set that matter down for a hearing. M. Ismail Sloan thereafter spent two years trying to get a hearing in that court, without success.

99. For this reason, M. Ismail Sloan consulted with a private lawyer named Michael Gamble for advice on what to do about this situation. Michael Gamble advised him to file a second custody petition in Amherst County, giving as the reason for this that Judge Janow in Amherst County had a different view of the law from Judge Harris in Lynchburg. (This turned out to be true). Michael Gamble was a former law partner of Judge Janow. The name of their firm had been Janow & Gamble.

100. For this reason, on January 13, 1986, Ismail Sloan filed a petition in the Amherst County Juvenile and Domestic Relations Court seeking custody of his daughter, Shamema Honzagool Sloan, even though he had never in his life resided in Amherst County. Previously, he had filed petitions in the Bronx Family Court, the Bronx Supreme Court and the Lynchburg Family Court for the same relief. One problem which he had repeatedly faced in these petitions concerned the fact that the mother of Shamema, Honzagool, had disappeared, and her lawyer, William J. Lake, had died. While his custody petitions had been essentially uncontested, he had been unable to obtain a clear order awarding him custody. He was having difficulty in raising up Shamema with an absent mother and no clear order awarding him custody. This led Ismail Sloan to try another court.

101. After the filing of a petition in Amherst, Judge Janow of the Amherst County Juvenile and Domestic Relations Court also refused to provide a prompt hearing on this matter. Instead, he kept postponing the case, stating that time was needed so that the mother, Honzagool, could be personally served by a process server. This was quite impossible, since Honzagool was a famous person in Pakistan and, for that reason and also for religious reasons, had kept herself in seclusion with her face hidden behind a veil. No man was allowed to contact her. This provided Judge Janow with the prefect excuse to keep the case before him while refusing to decide the case. Even to this day, nobody really knows exactly where Honzagool is. Her whereabouts are sought by many, including the newspapers in Pakistan and the prominent leaders of her tribe. Her mother in Pakistan claims that even she does not know where Honzagool is. The great-uncle of Honzagool is Prince Mohay-ud-Din, who was recently appointed as the Minister of State for Tourism and Development of Pakistan and who lives directly across the Chitral River, where he can see the house of Honzagool. He also does not know where she is. However, her mailing address is: Honzagool, c/o Zar Khan, Village Damik, P.O. Jinjoret, Drosh, Chitral, Pakistan.

102. Finally, after much procrastination and delay, Judge Janow scheduled a hearing for August 25, 1986. However, a few days before that date, Vickie Jennings, a member of the Court Service Unit, informed the court that she was going away on vacation and had not been able to prepare her report on time. This gave Judge Janow an excuse to further delay the hearing.

103. On or about August 21, 1986, Defendant Frank Davidson III happened to see Ismail Sloan on the premises of the Paul Monroe Elementary School in Lynchburg in the process of enrolling his daughter, Shamema Sloan, in kindergarten one. Shamema was then four years old. Frank Davidson III reported this to Charles and Shelby Roberts. They became excited about this because they were aware that Shamema was becoming old enough to start kindergarten and they wanted to enroll Shamema in the Temple Baptist School. This matter was of utmost importance to them, because the Roberts are fanatical followers of Jerry Falwell and Jerry Falwell instructs his followers not to allow their children to attend public school. The Roberts had also discovered that Shamema is a gifted child and they wanted to get her for that reason.

104. For this reason, Frank Davidson III contacted Judge Janow and informed him that he wanted a hearing on the matter of Shamema attending school, even though his clients were not actually yet parties before the court. Although Judge Janow had already canceled the previously scheduled August 25 hearing, he agreed to squeeze Frank Davidson in at the end of the day. Thus, Frank Davidson, representing a non-party, was able to get a hearing on less than four days notice, whereas Ismail Sloan, the natural father, had not been able to get a hearing after seven months.

105. No actual hearing was conducted on August 25 in that there was no live testimony of witnesses. Instead, there was a conference between lawyers in chambers. Present were Judge Janow, Frank Davidson III and Steve Martin, counsel for Ismail Sloan. The plaintiffs are not aware of what was said at this meeting. However, it appears that Judge Janow told Frank Davidson that he had no choice but to award custody of Shamema Sloan to Ismail Sloan because, up until that time, no other person, not even the mother, had filed for custody. Judge Janow however indicated that if Frank Davidson would be willing to file a custody petition, he might favorably entertain it. In the meantime, Judge Janow was willing to allow Shamema Sloan to attend the Temple Baptist Church and School.

106. After this lawyer's conference, Judge Janow read out his decision in open court. The decision was to award custody of Shamema to Ismail Sloan but to allow Charles and Shelby Roberts to enroll Shamema in Temple Baptist School. Ismail Sloan tried to object in open court, but Judge Janow would not allow him to say anything.

107. What Judge Janow did not realize, because he failed to conduct a fact hearing on that date, was that already Ismail Sloan had terminated the services of Shelby Roberts as a baby-sitter and had removed Shamema from the Roberts' home. The mother of Ismail Sloan, Helen Marjorie Sloan, had presented Shelby Roberts with a severance check in the amount of $5720 that morning. Ismail Sloan had also notified his lawyer, Steve Martin, of this and had informed him that under no circumstances would he return Shamema to Shelby Roberts. During the time of the meeting in court on August 25, 1986, Ismail Sloan and his mother had kept Shamema Sloan with a psychiatrist friend named Jesse Enslin.

108. It was absolutely impossible for Ismail Sloan to agree to allow his daughter to attend the Temple Baptist School, because both of the parents of Shamema, Ismail Sloan and Honzagool, were Muslims. This was especially true since Honzagool comes from a strictly religious family. It was also noteworthy that the decision of Judge Janow made no logical sense. If Ismail Sloan, a Muslim, had custody of Shamema Honzagool Sloan, how was it that Shamema Sloan was to attend the Baptist church and school near the home of Charles and Shelby Roberts?

109. At the same time, Plaintiff Helen Marjorie Sloan had been having trouble with her youngest son, Creighton Sloan, whom she had accused of stealing her money. She had already given $44,000 to Creighton in 1986 alone and still he wanted more money. Also, Creighton Sloan had stolen her car, an Audi, and was refusing to give it back. Helen Marjorie Sloan was further upset about the fact that Creighton Sloan was constantly threatening, badgering and harassing her and that he had never expressed any gratitude at all for the fact that she had financed his three master's degrees. For these reason, Helen Marjorie Sloan asked her other son, Ismail Sloan, to take her and Shamema Sloan to another state.

110. That very night, Ismail Sloan, Helen Marjorie Sloan and Shamema Sloan caught a flight from Roanoke to Pittsburgh, that being the last flight out of Roanoke that night. It so happened that at this particular time, Ismail Sloan was the manager of the three chess playing Polgar sisters of Hungary and had made a prior arrangement to take the Polgar sisters to Argentina for a chess tournament. For this reason, the three Sloans decided to accompany the three Polgar sisters to the World Under-16 Chess Championship in Rio Gallegos in Southern Argentina. While Ismail Sloan had been previously scheduled to attend this chess tournament, he had not expected to bring his mother and daughter along. They departed for Argentina on approximately September 13, 1986.

111. While they were in Argentina, Defendant Creighton W. Sloan canceled all of the credit cards of his mother, Helen Marjorie Sloan, and withdrew all of the funds from her various checking accounts. He did this by using a power of attorney which she had given him in North Carolina in 1984.

112. Because of this, Helen Marjorie Sloan was unable to pay her hotel bill in Rio Gallegos, Argentina and was threatened with arrest there. She contacted Creighton Sloan and her other relatives and pleaded with them to advance the funds necessary to allow her to check out of the hotel. All of her relatives refused to send her any money. Therefore, she sent a telegram to Sovran Bank and to Creighton Sloan notifying them that she was revoking his power of attorney.

113. As a result of this, Helen Marjorie Sloan was not arrested and put in jail in Rio Gallegos, Argentina, as she otherwise would have been had she not revoked that power of attorney. Rather, the tournament organizer there, after calling Sovran Bank, agreed to accept her personal check. Helen Marjorie Sloan was then free to leave Argentina.

114. Because of this incident, Helen Marjorie Sloan was afraid to return to the United States. She asked her son, Ismail Sloan, to find another country to take her to. After purchasing a globe at a local store and looking at all of the countries in the world in search of a safe sanctuary, they decided to go to the United Arab Emirates, one of the richest countries in the world and also one of the most difficult countries in the world to enter. Ismail Sloan was able to get a visa for himself and his family to enter that country only because the World Chess Olympiad was scheduled to start there and he was a recognized journalist.

115. Because Plaintiff Helen Marjorie Sloan was afraid to cross America for fear that her other son, Creighton Sloan, would try to have her arrested, as he had tried while she was in Argentina, they embarked on a circuitous route which led them through Brazil, Paraguay, Spain, France, Switzerland, Germany, Austria, Hungary and finally the United Arab Emirates. Along the way, Creighton Sloan tried to have his mother detained by the police in Paris, France, again without success.

116. Frustrated by the fact that his mother had successfully escaped from him, Creighton W. Sloan filed a suit in the Lynchburg Circuit Court on December 11, 1986 entitled <+#>"Creighton Sloan, son and next friend of Helen Marjorie Sloan against Sovran Bank<-#>." There were no other parties to this suit except for Creighton Sloan and Sovran Bank. Helen Marjorie Sloan was never and, to this day, has never been served with any form of notice or with a summons and complaint.

117. In spite of the lack of notice and in spite of the fact that Helen Marjorie Sloan was not named as an actual party, on the very next day, Defendant Judge Richard S. Miller ordered a freeze on the main bank account of Helen Marjorie Sloan at Sovran Bank and also allowed Creighton W. Sloan to operate all of the other Sovran Bank accounts of Helen Marjorie Sloan. Judge Miller stated that the "attempted revocation" of the power of attorney previously given to Creighton W. Sloan in North Carolina in 1984 was null and void because the revocation had "not been recorded". (It seems that Judge Miller did not realize that the power of attorney itself had also not been recorded in Virginia.) Judge Miller made this decision in clear absence of all jurisdiction to do so.

118. The order of Judge Miller was entered on January 2, 1987. Immediately after the entry of this order, Creighton Sloan withdrew all of the funds from all of the checking accounts of his mother at Sovran Bank. The only account which remained was the so called "Trust Account" which then contained about $125,000. That was the only account which Judge Miller would not allow Creighton Sloan to empty.

119. While all this was going on, Helen Marjorie Sloan was in the United Arab Emirates. She had no idea about the litigation against her bank (which was really a friendly suit). She first found out about it on January 7, 1987, when a check she had written on her Sovran Bank account bounced. Meanwhile, Creighton Sloan had either diverted or stopped her Social Security check and her monthly pension check from the Virginia Supplemental Retirement System.

120. For these reasons, Helen Marjorie Sloan was left in a foreign country completely destitute and without funds. However, she was still unwilling to return to the United States, because of the mistreatment which he had suffered at the hands of Creighton Sloan in the past. Therefore, she remained in the United Arab Emirates, but was completely dependent on her other son, Ismail Sloan, for financial support.

121. On or about February 2, 1987, Helen Marjorie Sloan signed under oath in the presence of John Lister, the United States Vice-Consul in Abu Dhabi as notary public, two documents, one of which revoked the 1984 power of attorney previously given to Creighton W. Sloan and the other of which gave a full and general power of attorney to her oldest son, Ismail Sloan. Both of these documents were, on February 11, 1987, recorded in the clerk's office of the Lynchburg Circuit Court. All interested parties were provided with copies of these recorded documents. However, the defendants herein tended to ignore them.

122. In particular, Defendants Sovran Bank and Massie G. Ware, Jr. refused to send to Helen Marjorie Sloan her periodic bank statements. The purpose of this was to conceal from Helen Marjorie Sloan the extent of looting which was going on in her bank account. They said that if she wanted the bank statements, she would have to get them from Creighton W. Sloan.

123. By about April or May, 1987, Helen Marjorie Sloan was finally able to get her social security check restored and sent to the American Embassy in Abu Dhabi, United Arab Emirates. This gave her a little bit of her own money. However, her pension check was still stopped. Finally, after repeated threats of litigation and the intervention of the Assistant Attorney General of Virginia in her behalf, Helen Marjorie Sloan was finally able to get her pension check restored in about September, 1988, after a hiatus of seventeen months.

124. Meanwhile, Ismail Sloan and his family were continuously harassed and threatened by Charles and Shelby Roberts, who were sending the State Department requests for information about the "whereabouts and welfare" of Shamema Sloan on a continuous basis. In response to one of these requests dated October 15, 1988 (which happened to be the seventh birthday of Shamema), Robert Murphy, the United States Consul General in Abu Dhabi, wrote a letter to Charles and Shelby Roberts which stated that "Shamema is the brightest child that I have ever seen" and which stated that Shamema was happy, healthy and progressing well in school. This was not the news that the Roberts wanted to hear. They continued the harassment of M. Ismail Sloan and his family.

125. During the period of four years when the plaintiffs were in the United Arab Emirates, they were constantly harassed by Defendants Charles and Shelby Roberts and by Defendants Creighton W. Sloan and W. Cassel Jacobson. In particular, Helen Marjorie Sloan was in the habit of going every month to the United States Embassy in Abu Dhabi to collect her monthly social security check. She did this in order to make sure that Creighton W. Sloan did not start stealing her social security checks again. On almost every occasion on which Helen Marjorie Sloan came to the embassy to collect her check, she was interrogated by the embassy staff regarding the voluntariness of her presence in the United Arab Emirates.

126. The reason for this was that the embassy was being bombarded with cables originating from Creighton Sloan and Cassel Jacobson stating that Helen Marjorie Sloan had been kidnapped by Ismail Sloan against her will and that Helen Marjorie Sloan had "Alzheimer's disease" and did not know what she was doing. In addition, Creighton W. Sloan had written to Senator Strom Thurmond of South Carolina demanding that Helen Marjorie Sloan be returned to the United States. On each of these occasions, Helen Marjorie Sloan informed the embassy that she did not have Alzheimer's disease, that she knew exactly what she was doing, and that she definitely did not want to go back and live with Creighton Sloan or to give Creighton Sloan any more money.

127. During this period of more than three years of constant harassment through the embassy, neither Creighton W. Sloan nor W. Cassel Jacobson ever contacted Helen Marjorie Sloan directly. They never called her on the telephone, much less come to visit her, as they would have done had they been seriously interested in anything other than her money.

128. In an effort to clear this matter, in June, 1988, Ismail Sloan went to Guam, U.S.A., where he surrendered to the U.S. Attorney and the F.B.I. on June 30, 1988. He was arrested, but was released after about two hours because the F.B.I. called the Lynchburg Police who in turn woke up defendant Bill Petty, the Lynchburg Commonwealth Attorney. Petty stated that Virginia would not be willing to pay the costs of extraction of Ismail Sloan from Guam to Virginia.

129. The main reason, other than to surrender, that Ismail Sloan had come to Guam, was to escort Vithanage Santhilatha, also known as Renuka, to America to give birth to her baby, so that the baby would be a born United States citizen. Therefore, Ismail Sloan proceeded to Honolulu, where he was arrested a second time. This time, after being detained for about five hours, he was released on the orders of a United States District Judge in Honolulu. Then, he went to California. (Renuka had proceeded him, catching an early flight out of Guam). Eventually the baby, Jessica Vithanage Sloan, was born on September 14, 1988.

130. About one week later after M. Ismail Sloan was twice arrested in June, 1988, all federal proceedings against Ismail Sloan were dismissed by a United States District Judge in Roanoke, Virginia. This is the reason that Defendant William H. Petty cannot now get M. Ismail Sloan arrested by the F.B.I., although he would like very much again to do so.

131. The purpose of these federal proceedings had not been to prosecute Ismail Sloan for violating any federal law. He had violated no such law. Rather, the purpose had been to escort him to Amherst County, Virginia, where he would be held in civil contempt by Judge Janow indefinitely until he agreed to surrender Shamema to Charles and Shelby Roberts, who wanted her. In other words, the arrests in Guam and Honolulu were false arrests in that they were made without any intention of securing a valid conviction under the federal crime for which he was charged, which was kidnapping. The sole purpose of these arrests was to help Charles and Shelby Roberts with their child custody suit which was still pending, and not actually to prosecute Ismail Sloan for any crime. This is the reason that defendant Petty had refused to pay the extradition costs.

132. Because of these developments, Ismail Sloan was free to enter and depart from the United States, but plaintiffs Helen Marjorie Sloan and Shamema Honzagool Sloan were not free because Creighton W. Sloan was trying to have his mother detained and Charles and Shelby Roberts were trying to have Shamema detained.

133. In July, 1988, while Ismail Sloan was still in America, Defendant W. Cassel Jacobson caused to be sent to the U.S. Embassy in Abu Dhabi a false cable stating that Ismail Sloan had been arrested and was in jail in Guam and that for this reason Helen Marjorie Sloan should return to the United States immediately. Because of this, the United States Consul General in Abu Dhabi, Robert Murphy, along with another embassy employee, personally went to the home residence of Helen Marjorie Sloan to inform her of this and to ask if she wanted to return. Helen Marjorie Sloan informed Robert Murphy emphatically that under no circumstances did she want to return to America.

134. In November, 1989, Helen Marjorie Sloan filed a suit in the Lynchburg Circuit Court against many of the defendants who are also named in this complaint in which she alleged that they were conspiring to force her to return to the United States against her will in order to get her money. She further alleged that Defendants Judge Janow, Charles Roberts, Shelby Roberts, Creighton Sloan, Frank Davidson III and others were conspiring to kidnap her granddaughter, Shamema Sloan. Named among the defendants was also Judge Miller who, she alleged, had no jurisdiction to freeze her bank account. This case was assigned by special designation by the Virginia Supreme Court to Judge Ernest W. Ballou in Roanoke.

135. The general situation remained essentially in status quo until December, 1989, when Ismail Sloan went to Chitral, Pakistan to visit the family home Honzagool, the mother of Shamema. While he was in Pakistan, Plaintiff Rankoth Pedigedera Dayawathie, who had just arrived back from Sri Lanka on November 30, threatened another resident of the family home, Plaintiff Linda Duavis, also known as "Philippine Linda", with a knife. Philippine Linda fled to the Philippine Embassy. The Philippine Ambassador, Fortunado D. Oblena, decided to get personally involved in this case, and started bringing pressure from a high diplomatic level on the entire family of Ismail Sloan. Oblena wanted to have Philippine Linda deported to the Philippines, in accordance with the policy of President Corazon Aquino of trying to prevent Philippine women from leaving the Philippines. However, Philippine Linda did not want to go back to the Philippines and the family of Ismail Sloan would not agree to send her by force. As a result, Philippine Linda was detained as a prisoner inside the Philippine Embassy and was not allowed to leave the embassy except under escort for the next one and a half years. These developments were part of a chain of events which eventually led to the present situation where the family members became vulnerable to kidnapping and then were actually kidnapped.

136. Because she was the one who actually caused this problem by threatening Philippine Linda with a knife, Rankoth Pedigedera Dayawathie was banished to America in March, 1990. Then, on about June 17, 1990, Shanti Vithanage suddenly called from Dubai Airport to announce that she was inside the airport with a boarding pass and was going to Sri Lanka to get married. She said that she was leaving Jessica with Ismail Sloan and was never coming back. Philippine Linda was still inside the Philippine Embassy in Abu Dhabi, having been detained there in "consular custody" on the personal order of the Philippine Ambassador. (To this very day, upon information and belief, Philippine Linda is possibly still inside the Philippine Embassy, and may remain there for some time). This left the 80-year grandmother, Helen Marjorie Sloan, the three children, and Ismail Sloan alone in their five bedroom house in Fujairah.

137. For this reason, Ismail Sloan took his family to the Philippines to try to recruit domestic help to care for his family and also to attend an interzonal chess tournament as a journalist. However, Fortunato D. Oblena, the Philippine Ambassador, had caused a notice to be posted on the wall of the airport that Ismail Sloan would not be allowed to enter the Philippines. Therefore, all five of them were sent to the next stop of that particular aircraft, which happened to be Bangkok. They arrived in Thailand on the morning of July 9, 1990.

138. Immediately, the same day as their arrival, the entire family went to the United States Embassy in Bangkok, where Ismail Sloan applied for a new passport, because his existing passport had been questioned not only by the Philippine authorities but also by one of the United States Embassy duty officers in Manila. The application was made to Defendant Stephen R. Pattison, the United States Consular officer in charge of American Citizen Services. Pattison told Ismail Sloan that he would have to send a cable to the State Department in Washington for authorization to issue a new passport.

139. On July 14, 1990, William Chronister and Robert Chipperfield of the United States Department of State "Fraud Prevention Program" sent a cable to Defendant Stephen R. Pattison authorizing and directing him to issue a new passport with full validity to Ismail Sloan. However, Defendant Stephen R. Pattison failed and refused to issue the new passport promptly, claiming at various times that he had not received the cable, that it had been misdirected or that it must have been mislaid. It later developed that the real reason that he was refusing to issue a new passport was that he had received cables originating from Edin Brown, a U.S. Consular officer in Sri Lanka, asking that a stop be placed on the passport of Ismail Sloan.

140. As a result, Ismail Sloan started coming to the United States Embassy in Bangkok every day. Usually, he brought his entire family with him, including his 80-year-old mother and his three children. In the evenings, he was calling William Chronister and Robert Chipperfield in Washington every few nights. Chronister and Chipperfield kept saying that they had sent the cable; Pattison kept claiming that he had never received it.

141. It eventually become apparent that what was really going on was that Charles and Shelby Roberts, through their constant demands for information on the "whereabouts and welfare" of Shamema Honzagool Sloan, had been informed by the State Department that Shamema was in Bangkok. They had been calling Stephen Pattison on the telephone asking that Shamema be detained there. They had informed Defendant Creighton W. Sloan that the family was in Bangkok. Creighton had called Pattison asking that his mother be detained there. For these reasons, Pattison kept making excuses as to why he was unable to issue a new passport for Ismail Sloan, thereby preventing him from leaving Thailand.

142. The reason that Charles and Shelby Roberts were able to get information from the State Department concerning the welfare and whereabouts of Shamema was due to a clerical error made (perhaps deliberately) by the Amherst County Juvenile and Domestic Relations Court which made it appear that they had been awarded custody, whereas in reality their custody petition was pending but they had never been awarded custody.

143. Although Defendant Frank Davidson III had instituted a suit for the custody of Shamema on August 27, 1986, he had never been able to obtain service of process because Shamema and her father were out of state and could not been served. Therefore, he had applied for an order of service by publication in the <+#>Amherst New Era Progress<-#>, a local county weekly. Based on this, and in total absence of all jurisdiction, Defendant Judge Janow had issued a court order plus an addendum to that order on either September 4 or 5, 1986. The order was ambiguously worded because one sentence seemed to give custody to Charles and Shelby Roberts, while another sentence seemed to give custody to the Amherst County Department of Social Services. However, the addendum to that order clarified that situation, by stating that "for purposes of interpretation and enforcement of this order" the court awards custody to the Amherst County Department of Social Services "with leave to place the child with any suitable persons, including Charles and Shelby Roberts."

144. The reason that Judge Janow had done this was that Virginia State law gives strong custody rights to the natural parents and Judge Janow, in spite of his personal sympathies and friendship towards the Roberts, could not legally give them custody of Shamema. Therefore, his plan was that the Amherst County Department of Social Services would be appointed as a stakeholder of Shamema, while Shamema would physically remain in the home of the Roberts, who would be appointed as "foster parents". In other words, Judge Janow decided that he did not want to comply with law of the State of Virginia requiring him to leave the child with the parents, and that he wanted to create his own law. He had adopted this method as a ruse to allow the Roberts to have physical custody of Shamema. The only problem with all of this was that the father and the child were not in the United States and, for that reason, he did not have jurisdiction.

145. Judge Janow did all of this on his own. He never consulted the Amherst County Department of Social Services about this. The Amherst County Department of Social Services never requested or petitioned for the custody of Shamema and indeed had never even seen her.

146. The apparent intention of Judge Janow was to direct the Amherst County Department of Social Services to use federal governmental funds and resources to contact other states, and to catch and detain Shamema, and have her extradited to Virginia. In this capacity, Judge Janow also caused to be issued a nationwide detention order for Shamema. This order had no immediate effect, because Shamema was in the United Arab Emirates at the time. However, because of this, Defendant Buster Walker and John, Stewart, Walker circulated thousands of "wanted" posters with photographs of Ismail Sloan, Shamema Sloan and Helen Marjorie Sloan. These wanted posters were generally published in real estate give away magazines which were distributed free in large quantities throughout America.

147. The problem which arose with Judge Janow's order was that the addendum which stated that "this court doth award custody to the Amherst County Department of Social Services" bore a type-written date of September 4, 1986, while the order to which it was an addendum bore the hand-written date of September 5, 1986. This made it appear that the addendum had pre-dated the order to which it was an addendum.

148. The docket sheet in the Amherst County Juvenile and Domestic Relations Court clarified the situation. The docket sheet contains a notation that the date of September 5, 1986 is an "error in date". However, Family Court files are normally sealed to the public. The State Department did not know about this "error in date". They therefore assumed that the order which bore the date "September 5, 1986" was the last order. That order appeared to give custody to Charles and Shelby Roberts. At the same time, Charles and Shelby Roberts kept asserting that they had legal custody, even though they well knew that this was not true. Sometimes, they even claimed that they had "adopted" Shamema.

149. As a result, Defendant William Crawford of the United States Department of State issued instructions to all consular posts around the world to provide all information which they had regarding the welfare and whereabouts of Shamema. William Crawford did not inquire diligently as to whether Charles and Shelby Roberts really had custody and, at the same time, Defendants Judge Janow and the other defendants who knew the true situation did nothing to correct this misapprehension on the part of William Crawford.

150. As long as they remained in the United Arab Emirates, this did not cause any major problem to the Sloan family, because Shamema was a Muslim child with a Muslim father, going to a Muslim school, reading the Holy Koran and being educated in the Arabic language medium. There was no way that the United Arab Emirates would hand such a child over to fanatical Christian fundamentalist Baptists like Charles and Shelby Roberts. The United States Embassy in Abu Dhabi knew that. However, once they left the United Arab Emirates and happened by chance to get stranded in Bangkok, with the connivance of a United States Consular Officer, Stephen R. Pattison, they were all at great risk. Plaintiffs Ismail Sloan, Helen Marjorie Sloan, Shamema Sloan, Michael Sloan and Jessica Sloan were all left stranded in Bangkok due to the refusal of Defendant Stephen R. Pattison to issue a new passport to Ismail Sloan.

151. The entire family had come to Thailand without any visa, because they had never intended to come to Thailand, having planned to go to the Philippines instead. They had been admitted at Bangkok Airport on a 14 day waiver of visa. Since they arrived on July 9, 1990, they were required to leave by July 23.

152. On July 23, not wanting to overstay illegally, the entire family went to the American Embassy Overseas Citizens Services and sat there for the entire afternoon. One reason for this was that their hotel, the Malaysia Hotel, had kicked them out that morning, probably because Helen Marjorie Sloan had gotten into an argument with a chamber-maid. They had experienced difficulty checking into another hotel because their visa waiver was expiring that day. This caused them to camp out in the United States Embassy. However, Defendant Stephen R. Pattison refused even to come to the window and speak to them. Finally, they were asked to leave at closing time.

153. However, because of the long wait all afternoon inside the United States Embassy, the 80-year-old mother, who had been perfectly healthy that morning, became ill inside the Embassy. She had trouble walking when she was leaving the Embassy. Finally, by 7:00 P.M., she could no longer stand by herself, and she had to be taken to the hospital.

154. At Bangkok General Hospital, Helen Marjorie Sloan was diagnosed as having pneumonia, bronchitis and high fever. She was admitted into intensive care. Later, she was transferred to her own private room. Within a few days, the virus which caused all this had been cured. However, she had lost a great deal of her cognitive power and could no longer stand up unaided. She refused to eat and had to be force fed through a feeding tube by her son, Ismail Sloan. She stayed in the hospital from July 23 until September 3, when she was kidnapped by Boonchoo and Sobell. During that entire period of about six weeks, her family, this being her son and her three grandchildren, stayed with her at her bedside all night every night.

155. On the morning of July 24, 1990, the day after Helen Marjorie Sloan had been admitted to the hospital, Ismail Sloan contacted Defendant Stephen R. Pattison and asked him to send a cable to the State Department in Washington, D.C. requesting that certain individuals be contacted for funds to pay the hospital and medical expenses of Helen Marjorie Sloan. He gave the names, addresses and telephone numbers of five persons to contact. These were: Creighton W. Sloan, W. Cassel Jacobson, Massie G. Ware, Jr., Judge Richard S. Miller, and Judge Ernest W. Ballou. This request was forwarded by Stephen R. Pattison to Defendant Marlee Anderson of the State Department Emergency Citizen Services. All of the above are named as defendants to this suit, with the exception of Judge Ballou.

156. The reason for this list of names was that all of them were in some way involved in the illegal freeze on the Sovran Bank account of Helen Marjorie Sloan, which had an estimated $160,000 in the account. These funds had not been touched in four years, and now they were needed to pay the necessary medical expenses of Helen Marjorie Sloan. Ismail Sloan wanted the hospital bill to be paid out of the money in that bank account.

157. On the same day, Defendant Marlee Anderson spoke to Defendants Creighton W. Sloan and W. Cassel Jacobson. They also spoke to each other. The end result was that they informed Marlee Anderson that they were not willing to allow any funds to be released from the Sovran Bank account, unless they had physical custody of Helen Marjorie Sloan first. Later on, Defendant W. Cassel Jacobson personally went to the office of Defendant Marlee Anderson and asked her assistance in helping them to obtain physical custody of Helen Marjorie Sloan.

158. On July 26, 1990, Ismail Sloan finally obtained the new passport from Stephen R. Pattison which had been denied to him for so long. Now, he was finally free to leave Thailand, but he could not leave, because in order to do so he would have to abandon his mother in the hospital. It is still not clear why Defendant Stephen R. Pattison suddenly relented and decided to give Ismail Sloan a new passport under such circumstances, just exactly after his mother got sick.

159. Now, a new pattern developed. Every day, Ismail Sloan called Stephen R. Pattison to find out if the money had arrived from Sovran Bank to pay the hospital and medical bills of his mother. Almost every night, he called America in the same connection. He not only called Marlee Anderson but he also called the clerk of the Lynchburg Circuit Court, various Lynchburg attorneys, various old friends of his mother, and various other people whom he thought might have influence to shake loose some money.

160. The reason that money never came was that, all this time, Creighton W. Sloan had been working to stop any funds from being transferred to pay the medical bills of his mother. Creighton Sloan had instructed his attorney, Defendant Killis T. Howard, to oppose any effort to pay the hospital bills of his mother. However, one relative on his own decided to sent money to pay the hospital bills of Helen Marjorie Sloan. When Creighton was unable to prevent that from happening, he left Aiken, South Carolina, went to the airport, got on an airplane, flew to Bangkok, Thailand, and showed up at the American Embassy, where he showed the revoked power of attorney which his mother had given him in 1984, and claimed the money for himself.

161. After that, Defendant Creighton W. Sloan hired Defendant Boonchoo. Creighton assigned the entire $4,000 to Boonchoo and gave Boonchoo a general power of attorney to represent him. He then returned to Aiken, South Carolina, without ever entering Bangkok General Hospital, without seeing his mother, and without even informing his mother, his brother, and the children that he had ever entered Thailand. Thus, the money which had been sent by the other brother of Helen Marjorie Sloan to pay her hospital and medical bills was never used for that purpose. Instead, that money was assigned to Boonchoo to pay his fees to file a court case against Helen Marjorie Sloan. Creighton Sloan, instead of going to visit his mother, who was believed to be nearly dying at the time, went to the police station and placed an interdiction order that his mother should not be allowed to leave the hospital and that, if she tried to leave or when she was healthy enough to leave, she should be arrested. He did this by presenting a certified copy of the order which Judge Miller had corruptly signed in January, 1987.

162. Meanwhile, the suit filed by Helen Marjorie Sloan, which was pending before Judge Ballou, was dismissed on July 19, 1990. Judge Ballou gave as the reason for his dismissal that Helen Marjorie Sloan was refusing to return to the United States and that for this reason any orders which he might issue could not be enforceable against her. A timely notice of appeal was filed on August 20, 1990.

163. The decision by Judge Ballou in effect gave a green light to the defendants herein to kidnap Helen Marjorie Sloan and her grandchildren. This is precisely what she was alleging that they were attempting to do in her lawsuit which Judge Ballou dismissed. Indeed, her kidnapping took place only about two weeks after she filed her notice of appeal. All of the persons involved in this kidnapping were persons who were either named as defendants to that suit or were their employees or agents or associates.

164. Ismail Sloan did not know about the existence of Boonchoo or that Creighton Sloan had ever been to Thailand until on or about August 24, 1990, when Boonchoo and John Sobell came to Bangkok General Hospital to see him. On that day, they demanded that Ismail Sloan hand the custody of Helen Marjorie Sloan over to them so that she could "go back home." They said that it would save a lot of trouble to Ismail Sloan to have his mother taken off of his hands. More than that, they promised to pay to Ismail Sloan the sum of $6,000 if her would agree to give his mother to them. At the same time, they threatened to cause a lot of trouble to Ismail Sloan if he did not hand his mother over to them peaceably.

165. During the approximately six weeks in which Helen Marjorie Sloan had been a patient in the Bangkok General Hospital, none of her relatives in America had contacted her. On the very first day of her hospitalization, an American lawyer in Bangkok named Harold Vickery had called to say that he had heard from Robert Jacobson, an old friend of his and a nephew of Helen Marjorie Sloan, that she was in the hospital. Robert Jacobson had obviously heard this news directly or indirectly from either W. Cassel Jacobson or Creighton W. Sloan, who had already been contacted by Defendant Marlee Anderson. However, other than that one call, the telephone never rang. Thus, it was known that all of the relatives of Helen Marjorie Sloan knew that she was hospitalized but, for their own reasons, none of them chose to call her. At various times during her hospitalization, Helen Marjorie Sloan had hovered near to the point of death. Thus, it had been shown that even when she was near to death, her son, Creighton W. Sloan, and her other relatives were not prepared to make their peace with her.

166. Ismail Sloan did not yet know that on the very day when Boonchoo and Sobell came to see him, Defendant Judge Richard S. Miller in Lynchburg had ordered Defendant Massie G. Ware, Jr. to send $6,000 out of the Sovran Bank account of Helen Marjorie Sloan through Defendant Marlee Anderson of the State Department to the American Embassy in Thailand to pay the hospital and medical bills of Helen Marjorie Sloan. Obviously, Boonchoo, who was in touch with Defendant Creighton W. Sloan, knew that this money was on the way, and further knew that once the money arrived, Helen Marjorie Sloan would be discharged from the hospital and would be taken to somewhere out of his reach.

167. Although the plaintiffs were completely unaware of this, there had been a flurry of activity going on about this in Lynchburg. The defendants were obviously hoping that Helen Marjorie Sloan was going to die, which would solve all of their legal problems, but they did not want to be seen as contributing too directly to achieve this goal. They had already withheld the funds necessary to pay the hospital bills of Helen Marjorie Sloan for six weeks and, nevertheless, in spite of all this, she was still alive. The hospital had not discharged her or put her out on the street in spite of not having yet received a penny, or a Thai baht.

168. Meanwhile, it had been discovered that during the period of seventeen months when Creighton W. Sloan had stopped his mother from receiving her retirement check from the Virginia Supplemental Retirement System, her Blue Cross Blue Shield medical coverage had also been canceled by that system. Thus, she had been left without any medical insurance whatever.

169. As a result of the conversation between Boonchoo, Sobell and Ismail Sloan, it came out that Creighton Sloan had been in Bangkok on August 10, 1990 and had hired Boonchoo on that date, and then had left the country. This was the first time that Ismail Sloan had ever been aware that Creighton had come to Thailand.

170. On Friday, August 31, 1990, in response to his daily telephone call to the American Embassy, Ismail Sloan was informed by Defendant Stephen R. Pattison that the amount of $6,000 to pay the hospital and medical bills of Helen Marjorie Sloan had arrived that morning. However, Defendant Stephen R. Pattison stated that for administrative reasons, the American Embassy could not process such a large amount of money in one day because "somebody has to go to the bank". He said that since the coming Monday was Labor Day and the Embassy would be closed, there would be no way to pay the bill and check Helen Marjorie Sloan out of the hospital until September 4, the day after Labor Day. Ismail Sloan observed that while $6,000 was presently enough to pay the entire bill, by Tuesday, September 4, the bill would exceed $6,000. Defendant Stephen R. Pattison replied that he was already aware of that, and for this reason he had already sent a cable to Marlee Anderson requesting more money.

171. In the meantime, Shanti Vithanage (also known as "Renuka") had returned from Sri Lanka to the United Arab Emirates, having changed her mind about getting married. When she had arrived back, she had found the Sloan family residence in the United Arab Emirates to be empty. She had gotten inside the house and had started making telephone calls. Due to a mistake by the telephone company, the telephone had not been disconnected, and Shanti started making excessive calls, eventually accumulating a bill of more than $2,700 on the telephone number of Ismail Sloan. Of utmost concern to her was what had ever happened to her daughter, Jessica. She called everyone she knew of, including Shelby Roberts and Creighton. Creighton had told her the telephone and room number of Helen Marjorie Sloan in the Bangkok General Hospital, although he had never called there himself. After that, she had started calling Ismail Sloan several times every day.

172. On the night of Sunday, September 2, Shanti called Ismail Sloan from Fujairah, United Arab Emirates, to warn him that either Cassel or Graham Jacobson were on their way to Bangkok to "catch Mama". Shanti told Ismail Sloan that he was going to be put in jail and that Helen Marjorie Sloan was going to be taken out of the country.

173. On the morning of September 3, not believing that things would develop so quickly, Ismail Sloan left the Bangkok General Hospital at about 11:00 A.M. to take an affidavit which his mother had signed to UPS, so that it would be sent by courier express to the Lynchburg Circuit Court and to various defendants to this case. When he returned at about 3:30 P.M., he discovered that his mother had been removed from the hospital and only his three children remained in the hospital room.

174. Helen Marjorie Sloan had obviously been kidnapped. She had been removed from the hospital in great haste. Her suitcase and all of her clothing had been left behind. Not even one personal article had been taken. Even her passport had not been taken, although it had been in the hospital room. She had been taken from the hospital room naked on a stretcher, wearing only a hospital smock.

175. Thereafter, Ismail Sloan inquired of the hospital staff what had happened to his mother. All of the members of the hospital staff professed to have no idea whatever had happened to her or where she had been taken, or by whom. It eventually developed that, in all likelihood, the hospital administrator had been bribed by Boonchoo to hand Helen Marjorie Sloan over to him, and had told his staff not to give Ismail Sloan any information whatever.

176. Ismail Sloan immediately thereafter called the American Embassy to inform them that his mother had been kidnapped. He spoke to the duty officer there, as the embassy was closed for Labor Day. The duty officer promised to investigate and to call him back. At about 5:00 P.M., the duty officer spoke to Ismail Sloan and told him that she did not know where his mother was but that, if she knew, she wouldn't tell him. She said that she would only say that his mother was "in a safe place, under a doctors care."

177. From this and other evidence, it became apparent to Ismail Sloan that Defendant Stephen R. Pattison was in on the fix and was in some way aware of or involved in the kidnapping of his mother.

178. Plaintiff Ismail Sloan stayed up the entire night of September 3 searching for his mother. With the assistance of the tourist police, every hotel, every hospital and every public facility in Bangkok was checked looking for her. A notice was put out on the police radio checking all points for an 80 year old woman from America in grave medical condition who was missing. Helen Marjorie Sloan was nowhere to be found. Ismail Sloan went to Don Muang Police Station, near the international airport in Bangkok, and obtained an interdiction order prohibiting the departure of his mother from the country on the grounds that she had been kidnapped.

179. On the morning of September 4, Ismail Sloan went to the American Embassy to report that his mother had been kidnapped. Defendant Stephen R. Pattison, with a smirk and a smile, said to Ismail Sloan, "If you think that your mother has been kidnapped, then you should go out and hire a private attorney."

180. On the same morning, Ismail Sloan went to the Makkasan Police Station, which is just outside the Bangkok General Hospital, and filed a written complaint that his mother had been kidnapped. However, the officer-in-charge of the Makkasan Police Station told Ismail Sloan that if he did not keep quiet about this, he was going to be arrested. Eventually, by complaining to his superior, Ismail Sloan got the officer-in-charge to summon Boonchoo to the police station. Boonchoo arrived at about 1:00 P.M. and demanded that the officer-in-charge arrest Ismail Sloan. However, Ismail Sloan was not arrested. Boonchoo admitted that he had removed Helen Marjorie Sloan from the Bangkok General Hospital, but said that he had the legal right to do so. In support of this, he produced a recently certified copy of the general power of attorney which Helen Marjorie Sloan had given to Creighton W. Sloan in 1984 (but which had been revoked in 1986 and again in 1987). Boonchoo also produced a power of attorney given to him by Creighton W. Sloan dated August 10, 1990, which gave Boonchoo "the power ... to commence legal action to obtain physical custody of Helen Marjorie Sloan." Boonchoo claimed that no legal action was needed. He claimed that Creighton Sloan already had the legal right to the physical custody of his mother pursuant to the 1984 power of attorney and the January 2, 1987 ex-party order signed by Defendant Judge Richard S. Miller, and therefore Boonchoo had removed her from the hospital without the need for filing any legal action. The officer-in-charge obviously accepted this contention, and Ismail Sloan was lucky to be able to leave the police station without being arrested.

181. On the early morning of September 5, Ismail Sloan went to the Don Muang International Airport to check to see if possibly his mother was going to be taken out of the country on Northwest Airlines Flight 28. In fact, he did not really believe that she would be removed from the country so quickly, because Ismail Sloan still had his mother's passport in his pocket and his mother could not be removed from Thailand without a passport. He also recalled that Defendant Stephen R. Pattison had taken 19 days to issue Ismail Sloan a replacement passport, and then only after checking with the State Department in Washington, D.C. He also knew that the State Department had been closed for Labor Day and also, because Bangkok is 11 hours ahead of the United States, the American Embassy in Bangkok had closed before the State Department in Washington had opened after Labor Day weekend. Therefore, Ismail Sloan knew that it had been physically impossible for Stephen R. Pattison to consult with the State Department in Washington since the time of the kidnapping of his mother.

182. Ismail Sloan was surprised to find Boonchoo at the airport with two suitcases on a trolley and a cellular telephone in his hand. When Boonchoo saw Ismail Sloan at the airport trying to stop his mother from being removed from the country, he called Defendant John Sobell on his cellular telephone. Sobell brought the police and Ismail Sloan was eventually arrested on a charge of "slander and defamation" of Boonchoo's character.

183. Boonchoo and Sobell thereafter spent six hours in the Don Muang Police Station trying to make sure that Ismail Sloan was arrested and that his passport was taken away from him. During this time, they were able to get Helen Marjorie Sloan, who was in nearly comatose condition due to knockout drugs given to her by Boonchoo, boarded onto Northwest Airlines Flight 28 under a false name. Northwest Airlines had been shown a copy of the interdiction order which Ismail Sloan had obtained prohibiting his mother from being removed from the country on the grounds that she had been kidnapped, but boarded her as a passenger anyway.

184. Ismail Sloan was actually only in the jail for about five hours on the slander charge. However, during this time, Boonchoo, Sobell and Defendant Stephen R. Pattison got the Bangkok Police to launch a search for the three infant children of Ismail Sloan. Boonchoo had been hired by Defendant Creighton W. Sloan not only to kidnap Helen Marjorie Sloan but also to kidnap the three children as well. Defendant Stephen R. Pattison did nothing in the way of contacting the police station to secure the release of Ismail Sloan, even though it was his duty as a consular officer to do so and Ismail Sloan had been jailed on a non-jailable offense.

185. In fact, Stephen R. Pattison could have obtained the release of Ismail Sloan instantaneously, because Boonchoo had asserted to the police that the American Embassy had given him the legal right to forcibly remove Helen Marjorie Sloan from Thailand. All Pattison had to do was inform the Bangkok Police that this was not true. In that case, Ismail Sloan would have been out of jail and Boonchoo would have been inside the jail. Instead, Pattison called Ismail Sloan on the telephone in the jail and demanded to know the whereabouts off the three children so that they could be handed over to the child welfare authorities. It must be pointed out that Thailand is a country where children are kidnapped and disappear with great regularity, so obviously the child welfare authorities are not doing a very good job. Thailand is also a country where anything can be achieved by bribing public officials. Once the child welfare authorities had the children, Boonchoo could easily have obtained them by paying a small bribe.

186. For these reasons, Ismail Sloan refused to give this information to Pattison or to cooperate in any way. The reason for this was that it had become obvious that Pattison himself was one of the kidnappers. There was no way for his mother to have been taken out off the country without a passport, and therefore it was apparent that Pattison must have provided Boonchoo with a passport in the name of Helen Marjorie Sloan so as to help him smuggle her out of the country. He knew that Boonchoo was a killer. If Boonchoo ever got a hold of his three children, they would never be seen again. Since Pattison was clearly a partner in crime with Boonchoo, Ismail Sloan was not going to give information to either one of them.

187. Since Ismail Sloan was not willing to cooperate, Boonchoo and Pattison had a nationwide police search launched for the children. As a result of this search, Boonchoo and Pattison were able to locate the three children in the Honey Guest House in Bangkok. Boonchoo attempted to have the children removed from the guest house by forcible means, but the guest house manager refused to give them up. Fortunately, Ismail Sloan was released from jail much more quickly than Boonchoo or Pattison had anticipated. Ismail Sloan got to the guest house and rescued the children from there before further actions could be taken.

188. Ismail Sloan could not leave the country because the police had taken away his passport. His lawyer, Prakob Sa-ngadsup, who was the national chess champion of Thailand and who had bailed him out of jail, spoke to Boonchoo about this. Boonchoo offered to drop the slander charges and have the passport returned, provided only that Ismail Sloan gave all three of his children to Boonchoo. Ismail Sloan took the three children by bus to the Golden Triangle area, 800 miles to the north, the one place in Thailand where the Bangkok Police cannot reach. Before leaving, he told the manager of the Honey Guest House that he was taking the children to Pattaya. Pattaya is in the opposite direction from the Golden Triangle, and he wanted to send Boonchoo, Sobell and Pattison looking for the children in the wrong direction.

189. A few days later, articles started appearing in all the Thailand newspapers, in both the Thai and English languages, including in the Bangkok Post, that Ismail Sloan had kidnapped his daughter, Shamema, from Charles and Shelby Roberts, who had "adopted" her on April 2, 1986. This, of course, was completely untrue. Charles and Shelby Roberts had never adopted Shamema, or even been awarded her custody. In fact, Ismail Sloan had been awarded custody of Shamema on April 2, 1986 and again on August 25, 1986, which was exactly the opposite from what the Bangkok newspapers said.

190. In spite of the complete untruth of these articles, this created an even more dangerous situation. While Ismail Sloan had hidden his children in a very safe place in the Golden Triangle area, even there newspapers are read and undoubtedly Ismail Sloan and his children would soon be recognized from these articles.

191. The articles also said that Shanti was being brought to Thailand by Boonchoo to seek the custody of her daughter, Jessica. Ismail Sloan therefore went around Bangkok looking for Shanti. By a stroke of great luck, they found each other in the long distance telephone call office.

192. What Ismail Sloan learned from Shanti was that Boonchoo had been hired by Charles and Shelby Roberts to kidnap Shamema and have her handed over to them in return for payment of $25,000 (twenty five thousand dollars). Already, a down payment had been made of twelve thousand dollars to Boonchoo. Charles and Shelby Roberts did not really want Michael and Jessica, but Boonchoo had told them that it would be difficult to kidnap just one child while leaving the other two behind. Therefore, Charles and Shelby Roberts, and Creighton Sloan who was also in on this, had instructed Boonchoo to kidnap all three children and then give away Michael and Jessica to anyone for adoption or dispose of them in some other way. Boonchoo and Sobell had told Shanti about this plan. They offered to give Shanti some money and also said that they would find a good home for Jessica somewhere. Shanti was afraid of losing her daughter. She had called Charles and Shelby Roberts, and they had instructed Boonchoo and Sobell to use some of the money they had sent, to bring Shanti to Thailand. Shanti had been rejected at the Bangkok Airport because she did not have a Thailand visa. Therefore, Boonchoo and Sobell had given her money and a return airplane ticket to Singapore. Shanti had gone to Singapore, obtained a Thailand visa, and come back to Bangkok, amidst much fanfare and newspaper publicity. Boonchoo had lodged Shanti in a house of prostitution for the night, apparently considering this to be a suitable place for Shanti. Shanti had escaped from the house of prostitution, and had run into Ismail Sloan in the telephone call office.

193. Together, Shanti and Ismail Sloan, in fear of their lives if they were ever caught by Boonchoo, fled to the Golden Triangle by bus, as the airports were clearly unsafe. The children were still there in safe condition, Michael having been spending his nights across the border in Burma. They collected the three children, and then took a bus to the South border of Thailand near Hat Yai, this involving a total trip of more than 1500 miles. Ismail Sloan knew that Boonchoo would have an interdiction order posted at every airport and border crossing point out of Thailand, in order to catch Ismail Sloan, Shanti and the three children.

194. Sure enough, when they arrived at the border check post at Hat Yai, they were spotted and detained within seconds. Fortunately, Ismail Sloan had brought with him a person whom he had met through his contacts in the Golden Triangle who was engaged in the regular business of smuggling illegal Burmese across that border. This person arranged the payment of a bribe of only twenty dollars to the Thailand officials, and with that small expenditure they were able to escape across the border into safety in Malaysia.

195. But not for long. A few days later, the five of them arrived in the United Arab Emirates, where they had lived in safety for four years. However, even that country was no longer safe. Defendant Eileen F. Lewison, the new United States Consular Officer in Dubai, had already spoken to Charles Roberts on the telephone and had given information to him about the whereabouts of Shamema. Also, the long forgotten Philippine Linda was still detained inside the Philippine Embassy. The Philippine Ambassador was still trying to have her deported and was in touch with the American Embassy and the Foreign Ministry of the United Arab Emirates about this.

196. Within about three days after their arrival in the United Arab Emirates, Charles and Shelby Roberts and Boonchoo found out that they had escaped from Thailand and had reached there. Boonchoo called up Shanti on the telephone, accused her of double crossing him (which was true), and told her that he was going to have her killed and her daughter given away for adoption if Shanti did not surrender Shamema. Boonchoo told Shanti to push Shamema outside the gate to the house and he was going to send two Thai men to collect her there, or otherwise she would be killed. Shanti looked over the wall and, sure enough, saw two Thai men standing there, this house being out in the desert where strangers never go. Shanti and Shamema locked all the doors and hid under the bed in Mama's room in fright.

197. When Ismail Sloan found out about this, he had all four of them taken to Abu Dhabi, 180 miles away, and hidden in the house of a man named Tamimi, a computer dealer from Tanzania. Ismail Sloan also had his telephone number disconnected. Tamimi kept them for about one week. Finally, Ismail Sloan decided that this was long enough, and took them back to their home in Fujairah on October 7.

198. Exhausted by the long drive from Abu Dhabi, Ismail Sloan took a nap at 1:00 P.M. When he awoke at 4:00 P.M., Shanti and the three children were gone. Shamema had left a note saying that they had gone to a marriage party in Dibba, about 50 miles north, and would probably not return until the following day. That evening, Shaikh Rashid, the ruler of Dubai and one of the richest men in the world, died, and the entire nation was placed under a five day curfew, during which all offices were closed and most traffic was banned from the roads. Due to this stroke of exceptionally bad luck, Ismail Sloan was not surprised when Shanti and the children failed to return home that evening.

199. It took a few days for Ismail Sloan to realize the truth, which was that all three of his children had been kidnapped. The actual kidnapper had been Shanti, but her actions were understandable. Shanti was tried of running from Boonchoo, who was threatening to kill her. The entire family was tired. The United States Department of State was tracking them around the world and there was no place left for them to hide. Charles and Shelby Roberts were willing to pay twenty-five thousand dollars to Boonchoo to kidnap Shamema and, for that amount of money, Boonchoo was prepared to follow them anywhere in the world. It was obvious that for that amount of money, he was easily prepared to kill Ismail Sloan and Shanti, and was quite capable of doing this. Even Ismail Sloan had decided to give up and go back to America, although his plan was to go to a different part of America where Charles and Shelby Roberts could not find them.

200. For that reason, Ismail Sloan had already obtained a United States visa for Shanti in Bangkok on September 13, the same day on which Shanti had her name in the Bangkok Post for coming to Thailand to bring a court case against Ismail Sloan. Ismail Sloan had also obtained a new Sri Lankan passport for Shanti on October 6, as Shanti's existing passport was out of pages due to traveling around the world with Ismail Sloan. On the afternoon of October 6, Shanti, Ismail Sloan and the three children spent one and a half hours inside the United States Embassy in Abu Dhabi, talking to Ronald Simkin, the United States Consular Officer, about the fact that they were being chased around the world by people who were trying to kidnap their children. Ismail Sloan complained about Defendant Eileen F. Lewison, who seemed to be especially inquisitive about the children. Simkin had assured them that nobody connected with the United States Embassy was in any way involved in a plot to kidnap their children.

201. What had happened was that Defendant Jay Roberts, the son of Charles and Shelby Roberts, had sent to Shanti three round trip tickets via TWA from Abu Dhabi to Washington National Airport and back. The cost of these tickets was $4448. The tickets were for Shanti, Shamema and Jessica. There was no ticket for Michael. The tickets were purchased at the Holiday Travel Agency on Church Street in Lynchburg and sent by telex through TWA for collection at the Albadie Travel Agency in Abu Dhabi. Albadie Travel Agency is the representative and general sales agent of TWA in Abu Dhabi.

202. Shanti took all three children to Abu Dhabi on the afternoon of October 7 and collected the tickets from the travel agency. Because there was no ticket for Michael, he had to be abandoned somewhere. First, Shanti took Michael to the American Embassy in Abu Dhabi and tried to leave him there. However, the embassy personnel refused to take him into custody or to accept responsibility for him. Because of this, Shanti decided simply to take Michael to Hamdan Street in Abu Dhabi, where she would let him get lost or just walk away from him. However, when she got to Hamdan Street to carry out this plan, it happened that Shanti met on the street a stranger named Jamal from Syria, who offered her a job as a housemaid. Shanti said that she did not need a job, but that her own housemaid, whose name she said was Linda Duavis (Philippine Linda), was looking for a job. Shanti got her and the three children invited to the house of Mr. Jamal for the night.

203. Early the next morning, Shanti told Mr. Jamal that she was going out to collect Philippine Linda and would be returning soon. She asked Jamal not to wake Michael, who was still sound asleep. Shanti went out with the other two children, and never came back. Instead of going to bring Philippine Linda, she went straight to Abu Dhabi International Airport, where she and the two children boarded a 9:00 A.M. flight to Kennedy Airport, with stops in Bahrain and London Heathrow Airport. They were checked in by TWA without any inquiry being made as to why eight-year-old Shamema was traveling without either of her parents.

204. At London Heathrow Airport, the three of them were detained briefly by the British and American authorities, who suspected that something strange was going on. They could not understand why Shamema, an eight year old child, was traveling without either her mother or her father. Shamema was also not registered as an unaccompanied minor, as she should have been in such a case. The British authorities considered sending them all back to the United Arab Emirates, from whence they had come. Finally, however, they allowed them to proceed on to America.

205. On the very early morning of October 9th, just after midnight, Shanti, Shamema and Jessica arrived at Kennedy Airport and from there were sent on to Washington National Airport, where they were greeted by the Roberts family, who had come up to collect them. From there, they were taken to the Roberts family home at 420 Amelon Road in Madison Heights, Virginia.

206. Meanwhile, Michael had been left behind in Abu Dhabi with a stranger named Mr. Jamal. Mr. Jamal waited in his apartment with Michael until that afternoon, when he realized that Shanti was not returning as promised. He therefore took Michael to the Al Asma Police Station in Abu Dhabi. Later, when Ismail Sloan went to the police station in Fujairah, 180 miles away, to report that his children were missing, the police were able to link the two cases together. Ismail Sloan drove to Abu Dhabi, where the police returned Michael to him.

207. Charles and Shelby Roberts had never been awarded custody of Shamema by Judge Janow. Instead, Judge Janow had awarded custody to the Amherst County Department of Social Services, in a clear absence of all jurisdiction to do so. When Ismail Sloan realized that his children had been stolen, he knew that Charles Roberts was behind this. Therefore, he called Ed Meeks, the Amherst County Commonwealth Attorney.

208. Meeks said that he knew nothing about this and suggested that Ismail Sloan call a Sheriff's investigator. A few days later, Ismail Sloan called Meeks again. Meeks informed Ismail Sloan that Shamema had been found in Amherst County. According to Meeks, Shamema was in the custody of the Amherst County Department of Social Services. He said that he had no information concerning the whereabouts of Jessica and Shanti.

209. About this time, Shanti called Tamimi and told him that she was in Sri Lanka with Jessica. Ismail Sloan notified the American Embassy in Abu Dhabi of this. Because an American citizen child was involved, the American Embassy in Colombo, Sri Lanka sent an investigator to the home of the grandmother of Shanti in Kalutara, Sri Lanka, but could not find Shanti or Jessica there.

210. At the suggestion of Ed Meeks, Ismail Sloan called Defendant Virginia Burks, Director of the Amherst County Department of Social Services. Mrs. Burks told Ismail Sloan that Shamema was in their custody "in a home which has been approved by the court." She refused to say whether or not that was the home of Charles and Shelby Roberts.

211. Thereafter, Ismail Sloan kept calling the office of the Amherst County Department of Social Services. They refused to give him any further information at all about Shamema. On October 15, 1990, Ismail Sloan called to say that he wanted to wish his daughter a happy birthday on the telephone, as that was her ninth birthday. The Amherst County Department of Social Services still refused to allow Ismail Sloan to talk to Shamema, even on her birthday.

212. Eventually, Ismail Sloan was able to learn through Plaintiff Rankoth Pedigedera Dayawathie that Shamema, Shanti and Jessica were all in the home of Charles and Shelby Roberts. Dayawathie was still in New York. She had been banished to there in March, because of threatening Philippine Linda with a knife. Ismail Sloan had never been able to go there, pick her up and take her back to the United Arab Emirates, as he had promised to do, became of these problems. She therefore had remained all this time in America and had become a valuable source of information.

213. In November, 1990, a warrant for the arrest of Charles Roberts and Vithanage Santhilatha ("Shanti") was issued by the public prosecutor of Fujairah, United Arab Emirates, in connection with the kidnapping of the three children. That warrant for arrest was transmitted through Interpol, to the Washington, D.C. office of Interpol, which is in the Department of Justice, on November 5, 1990.

214. In spite of this warrant for arrest on kidnapping charges, Charles Roberts has not been arrested. More than that, Defendant Virginia Burks and the Amherst County Department of Social, Services allowed Charles Roberts to keep Shamema in his home, in reckless endangerment of the welfare of Shamema.

215. Charles Roberts is heavily armed, with many rifles, shotguns and hand guns in his house. He keeps three guns loaded near the door. He says that the reason for this is that if Ismail Sloan comes to his house to try to see Shamema, he is going to kill him. The Amherst County Department of Social Services knows about this, and still allowed Charles Roberts to keep Shamema.

216. On November 8, 1990, plaintiffs Ismail Sloan and Michael Sloan arrived at Kennedy Airport in America. The first thing which Ismail Sloan did was call Rankoth Pedigedera Dayawathie, who was staying near Kennedy Airport. After Ismail Sloan had left her there in March, she had spent several months in the home of some Afghan refugees, whom Ismail Sloan knew from jail in Afghanistan in 1978, when one of them was a political prisoner. Ismail Sloan was indirectly responsible for all of these refugees coming to America, and they had been keeping Dayawathie in their apartment in Far Rockaway, Queens, New York, while she waited to give birth to George.

217. However, by November, Dayawathie was in the nearby home of Sharon Haberer. Although Ismail Sloan did not yet realize it, the Haberers were members of the same type of evangelical Baptist Church as is Charles Roberts in Madison Heights, Virginia and were already in touch with him. They had never seen Michael, but were interested in adopting them for themselves, just as Charles Roberts was interested in adopting Shamema in Virginia. When Ismail Sloan called Dayawathie from the airport, Sharon Haberer got on the telephone and invited him to bring Michael over.

218. Ismail Sloan did not bring Michael over. On the evening of November 10, David and Sharon Haberer, plus two men from their Community Bible Church, went to the apartment of the Afghan refugees and demanded to enter their apartment to see Michael. The Afghans told them that Michael was not there. On November 11, the same persons came again looking for Michael. Again, Michael and Ismail Sloan were not there. On the same day, Ismail Sloan took Michael to Lynchburg, Virginia.

219. On November 9, just after arriving in America, Ismail Sloan had called Ed Meeks on the telephone. Meeks had already received a lengthy affidavit plus exhibits which Ismail Sloan had filed by mail in the Amherst County J & D Court protesting the kidnapping and abduction of Shamema, demanding her return, and also demanding that Judge Janow disqualify himself from this case, as Judge Janow had clearly given his approval to this kidnapping. Meeks told Ismail Sloan that Judge Janow was a "fair minded person" who was going to step aside if his involvement in this case was causing any trouble or apprehension of the part of Ismail Sloan. Meeks then had Rick Groff of the Amherst County Department of Social Services connected on the same line. Rick Groff was introduced as the social worker on the Shamema case.

220. Meeks and Groff told Ismail Sloan that if he came down to Amherst, Virginia, Groff would arrange for Ismail Sloan to meet Shamema face to face so that he could verify that Shamema was still all right. Meeks also said that this meeting would serve another purpose. Apparently, since her arrival in the United States, Shamema had not been talking to anybody at all. The school authorities and the social workers had not been able to communicate with her. They, therefore, could not determine from her exactly how she happened to arrive in America. They had apparently also discovered that Shanti is a notoriously unreliable person when it comes to telling the truth. Meeks proposed that Ismail Sloan authorize Shamema to tell Groff how she had come to America, so that he could get this information privately. On the basis of this agreement, Ismail Sloan agreed to come to the offices of Meeks and Groff on Tuesday, November 13. (Monday was Veteran's Day.)

221. On the morning of November 13, Ismail Sloan took Michael to the offices of the United States Attorney in Roanoke, Virginia, where he had a meeting with Assistant U.S. Attorney Ray B. Fitzgerald and John Terry, the F.B.I. agent assigned to this case. Ismail Sloan complained to Fitzgerald and Terry that there was an international warrant for the arrest of Charles Roberts on a charge of kidnapping his two daughters and still not only had Charles Roberts not been arrested, but the two daughters, Shamema and Jessica, were still in his house. John Terry opined that because the kidnapping had occurred in a foreign country, the United Arab Emirates, the F.B.I. had no jurisdiction over this. He admitted that he had not really started any investigation at all and had not interviewed anybody, in spite of having received voluminous documentation about this kidnapping from Ismail Sloan some weeks earlier.

222. Ismail Sloan told Fitzgerald and Terry that one reason that he had brought Michael along was that he was sure that the next thing which was going to happen was that these same people were going to try to kidnap Michael. Terry said that if Michael is kidnapped, then the F.B.I. will have jurisdiction.

223. On the afternoon of November 13, Ismail Sloan went with Michael to Amherst to the office of Ed Meeks, the Amherst County Commonwealth Attorney, as he had promised to do. Meeks was not present and his secretary told him to go to see Rick Groff at the Amherst County Department of Social Services.

224. When Ismail Sloan entered the Amherst County Department of Social Services, Groff invited him and Michael into his office. He then left the office for a few minutes. Groff returned with Defendant Michael W. Cox, the Amherst County Sheriff, who proceeded to arrest Ismail Sloan. Groff presented Ismail Sloan with an order of Judge Janow of the Amherst County J & D Court dated October 24, 1990 which enjoined Ismail Sloan from having any contact with his daughter, Shamema Sloan. That was the first time which Ismail Sloan had been aware of any such order. Thus, it became clear that Rick Groff never had any intention of allowing Ismail Sloan to see his daughter face to face and had lured him into his office just for the purpose of having him arrested.

225. At the time of this arrest, Michael Cox asked Groff what they should do about Michael Sloan. Cox obviously wanted to take Michael into custody as well. Groff, however, said that there was no basis for that. He agreed that Michael could be given to a man named Jack Robinson, who had driven them out to Amherst County, to be taken back to Lynchburg.

226. After Michael had been taken back to Lynchburg, Ismail Sloan was brought before Magistrate Dudley. The charges against him were two charges of contempt of court dating back to 1986. One charge was failing to appear in court on September 8, 1986. The other was for disobeying a court order dated August 25, 1986, the same day that Ismail Sloan and his mother had left Lynchburg with Shamema.

227. In fact, these charges were frivolous and completely without merit. The reason that Ismail Sloan had never appeared in court on September 8, 1986 was that he had never been served with the summons. This date was based on the custody petition filed by attorney Frank Davidson III, a defendant herein, for the custody of Shamema. However, Davidson had filed his petition on August 27, after Ismail Sloan and Shamema had already left the state. Therefore, service had never been made. Apparently, Judge Janow had entered an order giving Frank Davidson leave to serve notice by publication in the Amherst New Era Progress, a local county weekly, but Ismail Sloan, not surprisingly, does not read that newspaper.

228. The charge that Ismail Sloan had violated the August 25, 1986 order was equally frivolous. That order gave him legal custody of Shamema Sloan. Otherwise, it did not order him to do anything. The order said that Charles and Shelby Roberts were "allowed to enroll Shamema Sloan in the Temple Baptist School." However, Ismail Sloan was not ordered to do anything. Finally, it gave reasonable visitation to Charles and Shelby Roberts "as counsel agrees". There had been no agreement between the counsel regarding visitation.

229. In spite of the frivolous nature of the charges, Magistrate Dudley set the bail at $1,000 (one thousand dollars) and remanded Ismail Sloan to the Amherst County Jail.

230. At 6:30 P.M. that night, Ismail Sloan was brought from the jail to the Amherst County J & D Court of Judge Janow. Judge Janow explained that he had come in that night especially to reopen the court to hear this case, because he was going to be out of town the next day and he wanted to make sure that no other judge would hear this case. He said that he had read the papers which Ismail Sloan had filed from Fujairah, United Arab Emirates, which complained about his children being kidnapped.

231. Ismail Sloan said that the Amherst County J & D Court had no jurisdiction over this case because his children were residents of the United Arab Emirates, the mother of Shamema was at all times in Pakistan, and the only reason that Shamema was now in Amherst County was that she had been kidnapped to there by Charles Roberts. Ismail Sloan said that Judge Janow had no jurisdiction over this case and the entire matter ought to be dismissed and the children restored to him. Ismail Sloan also repeated his often made demand that Judge Janow disqualify himself from this case on the grounds of personal bias and prejudice, among others.

232. In response, Judge Janow said that he had continuing jurisdiction over this case dating from 1986 because he had awarded custody to the Amherst County Department of Social Services "before anything could even be filed in Abu Dhabi." He said that he was going to hear this case and that it was "extremely unlikely" that he was going to disqualify himself. Regarding the contempt charges, he stated that he intended to sentence Ismail Sloan to one full year in jail (the maximum allowed, according to him). Finally, he stated that the earliest date that he would be able to hear the custody case would be February 4, 1991 (almost four months in the future) and that Shamema would remain with the Roberts until that time.

233. Finally, Judge Janow raised the bail set by Magistrate Dudley from $1,000 to $10,000. He said that he was increasing this bail in order to make sure that Ismail Sloan would not be able to contact his daughter Shamema Sloan. After that, he ordered Ismail Sloan to be taken back to the Amherst County Jail.

234. A few days earlier, Judge Janow had ordered the withdrawal of Steve Martin as counsel of record for Ismail Sloan, after Steve Martin had filed a motion to dismiss the child custody petition filed by the Roberts on the grounds that the Roberts had illegally acquired possession of Shamema through self help. As a result of this disqualification of counsel, the motion of Steve Martin to dismiss the child custody petition for lack of standing was never heard and Ismail Sloan was now in jail without counsel. The next day, Ismail Sloan borrowed a legal pad from one of his fellow prisoners and wrote out by hand a notice of appeal to the Amherst County Circuit Court, which one of the police officers in the jail agreed to take over to that court. After that, the court assigned an attorney to him named James H. Massie. Massie was able to set up a bail hearing before Judge Goad of the Amherst County Circuit Court for November 16. This bail hearing, including adjournments, lasted all day.

235. Ed Meeks, the Amherst County Commonwealth Attorney, finally conceded at the hearing that it appeared that the two contempt charges against Ismail Sloan were frivolous. He said however that this was a matter entirely up to Judge Janow and the Commonwealth Attorney had no right to say anything about this. Eventually, Judge Goad decided that he did have appellate jurisdiction to modify the bail (which was apparently the main legal question) and he lowered the bail back down to the original $1,000 set by Magistrate Dudley, while stating that Ismail Sloan should agree not to contact his daughter, Shamema Sloan, and should not leave the State of Virginia.

236. During that day, Ismail Sloan had been served by the police with custody petitions for his other two children. A petition for the custody of Jessica Sloan was made returnable in the Amherst County J & D Court on December 19 and a petition for the custody of Michael Sloan was made returnable in the Lynchburg Family Court on December 21. By 10:00 P.M. that night, Ismail Sloan had raised the bail and was out of jail. He was told to return to court on December 19 at 9:30 A.M. In the meantime, however, his last remaining child, Michael Sloan, had also been kidnapped.

237. On the morning of November 14, 1990, Charles Roberts had called his co-religionist, Defendant Sharon Haberer, on the telephone to inform her that he had gotten Ismail Sloan locked up in jail. He told her that Michael was also in Lynchburg and that if she wanted Michael, this was an opportune time to come down and snatch him. He had also given her the telephone number of Captain Coffey of the Police Department.

238. Sharon Haberer called Captain Coffey and confirmed what Charles Roberts had said. Therefore, Sharon Haberer arrived by Greyhound Bus in Lynchburg on the morning of November 16. She went to the Lynchburg Family Court to file a custody petition for Michael, apparently having been advised by attorney Frank Davidson III or some other Lynchburg attorney to do so. Then, she went in search of Michael. She went to the Sloan family residence at 917 Old Trent's Ferry Road and inquired of the neighbors, but they told her that they did not know where Michael Sloan was.

239. Sharon Haberer contacted Defendant Officer F.D. McFarland of the Lynchburg Police Department. Officer McFarland contacted Defendant Michael W. Cox, the Amherst County Sheriff. Michael Cox remembered the name of Jack Robinson, the man who had taken Michael Sloan back to Lynchburg at the time of the arrest of Ismail Sloan on November 13. Officer McFarland took Sharon Haberer to the house of Jack Robinson. He said that a family friend of Ismail Sloan had hired a baby sitter to care for Michael and directed Officer McFarland to the address of that woman. That woman sent him to yet another address. Eventually, after a long search involving looking down the pants of many small children, they finally found Michael. playing in the yard outside of the baby-sitters house. Sharon Haberer ran and snatched Michael and jumped into the police car. They were taken to the Greyhound Bus Station and put on a bus for New York City.

240. Defendant Officer McFarland did not know anything about this and did not question the story being told to him by Sharon Haberer. He did not even ask her for a driver's license or other identification to prove who she was. He apparently believed that Sharon Haberer was the mother of Michael. As a result, Sharon Haberer was just allowed to take Michael Sloan to the Greyhound Bus Station, where she boarded a bus with him to New York City.

241. While Officer McFarland was taking Sharon Haberer around Lynchburg looking for Michael, Ismail Sloan was all day in the Amherst County Circuit Court before Judge Goad. By the time he got out of jail that night, Michael Sloan was almost back to New York City. The next morning, Ismail Sloan called Sharon Haberer on the telephone. She admitted that she had taken Michael and said that Michael had finally arrived in a "good home". After that, she hung up the telephone.

242. Thereafter, Ismail Sloan called the Lynchburg Police Department and asked to speak to Officer McFarland. He spoke to Officer Hawkins and various other police officers. He was told that Officer McFarland had gone away on vacation for a week. He was further told that the only person who knew about this was the Amherst County Sheriff. When Ismail Sloan said that he wanted to come down to the police station to file a complaint that his son had been kidnapped, he was told that if he did that he was going to be arrested, because Stan Ogden of the Virginia State Police was looking for him.

243. Ismail Sloan therefore got on a bus and went to New York City. Early the next morning, he showed up at the 101 Precinct in Far Rockaway, New York City. The police agreed to go to the house of Sharon Haberer to question her about the kidnapping of Michael. Sharon Haberer gave them the names and telephone numbers of various police officers in Lynchburg, Virginia. The police came back to the police station and called those numbers.

244. Two days later, The Reverend David E. Haberer spoke to Ismail Sloan on the telephone and asked him to come by his house at 1105 Neilson Street in Far Rockaway to talk about this case. The Reverend Haberer tried to induce Ismail Sloan to enter on to his property, but Ismail Sloan remained on the sidewalk while they were talking. Within a few minutes, a police car came up behind him. Ismail Sloan was arrested and handcuffed by Officer Handibode. After he had been arrested, Sharon Haberer came out of the house and identified him. This was the first time in his life that Ismail Sloan had ever seen Sharon Haberer, even from a distance.

245. Sharon Haberer said that Ismail Sloan was wanted for kidnapping, rape, bigamy, polygamy and a wide variety of other crimes in various countries and other jurisdictions all around the world. The police took him to the police station and started calling a bunch of names and telephone numbers which had been given to them by Sharon Haberer and also apparently by the Lynchburg police. After all afternoon and more than a dozen long distance telephone calls, Officer Handibode remarked that it seemed that everyone in the entire world had heard of Ismail Sloan, but nobody wanted him for any crime.

246. After being held in jail for 30 hours, Ismail Sloan was produced in the Queens Criminal Court. The only charge against him was "aggravated harassment". The complaint, in its entirety, said that Ismail Sloan had called Sharon Haberer on the telephone and uttered the following words: "If you don't give my child back, you will pay." Apparently, she was claiming that Ismail Sloan had made this statement to her when he had called her from Lynchburg, on the morning of November 17, the day after Michael had been kidnapped. This was the only time that Ismail Sloan had spoken to Sharon Haberer since.

247. Fortunately, Judge Kron did not buy this agreement. He observed that the only charge before him was that Ismail Sloan had said, "If you don't give my child back, you will pay." He observed that there was nothing wrong with saying that and that the complaint was legally insufficient. Therefore, he ordered that Ismail Sloan be released on his own recognizance, but that he should return to court on December 5.

248. After that, the case was adjourned for several more times. Ismail Sloan had to keep traveling to New York City to appear in court. Each time the case was adjourned because the A.D.A. kept saying that they needed to investigate to see if there were any other charges pending against Ismail Sloan around the world. On January 24, 1991, when they finally concluded that there were no other charges, the case in Queens was dismissed.

249. On about the end of December, 1990, M. Ismail Sloan was able to get a telephone hooked up in the house at 917 Old Trent's Ferry Road in Lynchburg. This enabled him to keep in regular contact with Dayawathie in New York and Shanti in the Roberts house, both of whom started calling him collect. With this development, things started moving back in his direction. On Monday, January 7, 1991, Ismail Sloan engineered the escape of Rankoth Pedigedera Dayawathie and their two sons, Michael and George, from the house of Sharon Haberer. Rankoth Pedigedera Dayawathie made an appointment with Ismail Sloan to meet in front of a laundromat two blocks from the house of Sharon Haberer during the ten minutes at noon when Sharon Haberer customarily picks up her daughter from the church. Via a circuitous route, M. Ismail Sloan took Rankoth Pedigedera Dayawathie and their children to his house in Virginia. Meanwhile, Sharon Haberer called the police, the F.B.I. and every other authority she could think of to report that the two children had been kidnapped. On the basis of these complaints, the Lynchburg police came to the house of Ismail Sloan on about January 15 and verified that the mother and the two children were there on a voluntary basis and there was nothing wrong in the house.

250. The reason that Rankoth Pedigedera Dayawathie had been interested in running away from the house of Sharon Haberer was that she had come to the realization that Sharon Haberer was pretending to be so nice to her only because she wanted to adopt or give away for adoption her two children, Michael and George.

251. Thereafter, Shanti and Shamema contacted M. Ismail Sloan and informed him that they also wanted to run away, because they did not like the house of the Roberts. They made a plan to run away on the evening of Saturday, January 19. Under normal circumstances, the Roberts never let Shamema out of their sight, except when she is under armed guard in the church. Shanti and Shamema talk to each other in the language of Singhala, a language which the Roberts do not understand. On that particular Saturday, the Roberts had been invited to a church social and the children were not allowed to come. This gave Shanti and Shamema their first opportunity to run away. In preparation of this plan of escape, Shanti delivered the passport of Shamema, which had been taken by Charles Roberts, to Ismail Sloan.

252. However, Shanti wanted to discuss this first. She made an appointment to meet M. Ismail Sloan at the K-Mart in Madison Heights on Friday afternoon. However, when the appointed time came, Ismail Sloan could not get the car started. A tow truck had to be called. Several hours later, they finally got the car working again. By that time, it was evening. The appointment had to be re-scheduled. Shanti asked Ismail Sloan to pick her up in front the Winn Dixie, which is closer to the house of the Roberts. Ismail Sloan picked her up, but by chance they were spotted by a friend of the Roberts and the Roberts reported it to the police. The police followed them around Lynchburg by car and monitored them at the Burger King, where Shanti, Jessica, Dayawathie, Michael and George all had dinner together. M. Ismail Sloan took Shanti and Jessica back and dropped them off near the house of Roberts. When Shanti and Jessica entered the house, Charles Roberts was standing there with a pistol in his hand and Shamema was crying. The Amherst police were called. Shanti and Jessica were taken to the police station. Richard Groff was summoned and he took Shanti and Jessica to the Economy Lodge in Madison Heights for the night.

253. On Monday morning, Richard Groff took Shanti and Jessica to a homeless shelter in Roanoke. The reason for this was that Judge Janow had corruptly ordered on December 19, 1990 that Shanti and Jessica could not have contact with Ismail Sloan. Since the Roberts were not willing to keep Shanti and Jessica in their house any more because they were by then aware of the plan for Shamema to run away, there was no place to put Shanti except for in a shelter. Otherwise, Shanti and Jessica had no place to go. There was still Judge Janow's order prohibiting them from having contact with Ismail Sloan. Therefore, Rick Groff took them to a homeless shelter in Roanoke, for the purpose of keeping them away. Shanti immediately called Ismail Sloan from the shelter and told him where she was. He went to Roanoke to pick her up. However, the shelter officials had heard about this and had moved Shanti and Jessica to another shelter so that he could not find them. He then drove back to Lynchburg and waited for the next call. The next day, Shanti called again. Again, he drove to Roanoke. Again she had been moved. Again he drove back. Again, they called, and so on. This went on for three or four days. Finally, he secretly met her, picked up her and Jessica, and drove them back to his home in Lynchburg.

254. The two women from Sri Lanka, Shanti and Dayawathie, and the three children, were together in that house for only about three days. Ismail Sloan had to drive 420 miles to New York to attend the case Sharon Haberer had brought against him for "harassment". The case there was then immediately dismissed on the motion of the A.D.A. Ismail Sloan then turned around and drove back to Lynchburg. When he got to Lynchburg, he discovered that his nine-month-old son, George. was seriously ill. He took George, along with Michael and their mother Dayawathie, to the Virginia Baptist Hospital, where George was admitted. When he returned to the house a few hours later, Shanti and Jessica were missing. Officer Royer and five other police officers, acting on instructions originating from Judge Janow (who, it must be recalled, has no jurisdiction over Lynchburg) had been to the house and had escorted Shanti and Jessica from there. A few days later, Shanti and Jessica wound up in Oakland, California.

255. After that, M. Ismail Sloan pursued every known legal remedy to get his family back. He filed appeals, he filed suits, he filed mandamus petitions, he filed motions for writs of prohibition, he complained to the Judicial Inquiry and Review Commission, he handed out handbills at the polling places.

256. During this entire time, Judge Janow had pigeonholed the case and had refused to conduct a hearing. It must be recalled that no hearing had ever been held on this case in 1986. There had been no hearing regarding Shamema in 1990 as well. Judge Janow had taken all of these actions on an ex-party basis, without any fact hearing at all. The first hearing ever in this case was set for February 4, 1991.

257. At the outset, Judge Janow said that he was not prepared to decide the case on that day because he did not want for there to be any appeals, and therefore he wanted a three month adjournment. However, the five assembled attorneys all refused to agree. Therefore, an eight hour hearing took place. The end result was the same. Judge Janow adjourned the case for three months, However, the Amherst Department of Social Services insisted that M. Ismail Sloan should be allowed to have visitation with his daughter. Therefore, Judge Janow agreed to issue an order providing for that.

258. This order gave M. Ismail Sloan the first opportunity to appeal since the case had started in 1986. He promptly appealed to the Virginia Court of Appeals. However, the Virginia Court of Appeals, apparently not having a clear understanding of the facts of this case, dismissed the appeal as an appeal from a non-final order. This left M. Ismail Sloan without remedy for another three months.

259, However, as a result of this order, M. Ismail Sloan did finally get to see his daughter Shamema for the first time in all these months since she was kidnapped. Dayawathie, Michael and George had still remained in his house. Richard L. Groff started bringing Shamema to the house for visitation. Rick Groff discovered that whenever Shamema came to the house of her father, she became talkative and cheerful, whereas she was somber, sullen and non-communicative in the house of Roberts. In fact, Groff stated that he had never even heard the voice of Shamema until he brought her for the first time to her father's house.

260, This made Groff realize that the actual child abusers are the Roberts themselves. He then asked his new director, Defendant James Oliver, for permission to remove Shamema from the house of Roberts and at least place her with another foster family. They could not return Shamema directly to the house of her father, because Judge Janow had issued an order prohibiting that. However, defendant James Oliver called Judge Janow and spoke to him about it. Finally, James Oliver concluded that they should leave Shamema in the Temple Baptist Church and School and therefore with the Roberts for a few more weeks until the end of the school year, and then move her to Bedford County.

261. The last day of school was Friday, May 24. Richard Groff had by then arranged a new foster home for Shamema in Bedford County, where the Roberts could not find her. At 5:00 P.M., her normal time for being brought to the Roberts house from school, Richard Groff went to the house of the Roberts to pick up Shamema and take her to her new foster home. However, Shamema was not there. Perhaps by a stroke of luck or perhaps because they had been tipped off, Charles and Shelby Roberts had taken Shamema directly from the last day of school to Hilton Head Island in South Carolina, without ever stopping off at their house where Richard Groff was waiting for them.

262. This was in violation of the order of Judge Janow which said that Shamema was not to be taken out of state. Ismail Sloan wrote a letter to Judge Janow complaining about this, but to no effect. The next scheduled court date was June 24. Prior to that date, the Roberts brought Shamema back from South Carolina. Richard Groff still wanted to remove Shamema from their home and spoke to Ed Meeks and James Oliver about this. However, James Oliver said that since the court date was by then only ten days away, they might as well wait to see what the judge would decide. However, Richard Groff decided to write a letter to Judge Janow explaining the situation. He wrote the letter by hand and gave it to his secretary for typing. However, by the time of the court date, the secretary had never got around to typing the letter.

263. At the hearing on June 24, Richard Groff testified that they had thoroughly investigated all of the accusations made by Charles and Shelby Roberts against M. Ismail Sloan and had found them all to be without factual basis. He further testified that the Amherst County Department of Social Services had concluded that it was under a legal obligation to return the child to the father, as mandated by the social services law. Ed Meeks, the Amherst County Commonwealth Attorney, and J. Thompson Shrader, the Court appointed Guardian Ad Litem for the child, both recommended in favor of returning the child to the father.

264. In spite of this, Judge Janow corruptly awarded custody to Charles and Shelby Roberts. He gave as the reason for this the fact that M. Ismail Sloan had been critical of the courts and of the entire judicial system, as well as of himself personally, throughout this case. In particular, he made reference to the fact that M. Ismail Sloan had filed a complaint with the Virginia Judicial Inquiry and Review Commission against Judge Janow regarding his handling of the case. Judge Janow therefore concluded that a man who does not respect the judges of the courts should not be allowed to have the custody of his children. He said that he would write an order to that effect. He also conducted a five minute hearing in which he convicted M. Ismail Sloan of contempt of court going back to September 8, 1986. That was a contempt case which, all this time, he had left pending by Judge Janow, who was refusing to hear it.

265. Prior to the written order, which was entered one month later, M. Ismail Sloan had one last chance at visitation with his daughter. That took place on July 15, 1991. By this time, Dayawathie was pregnant with her next baby, Anusha, and had been taken by M. Ismail Sloan to New York. Shamema was disappointed that she did not get to see at the time of visitation her two little brothers whom she loves very much. She brought a wrapped birthday present for the third birthday of her brother Michael, who was born on July 18, 1988. She never got to deliver that birthday present, and may never see her brother again for many years, all due to the criminal activities of Defendant Judge Janow.

266. After that, Judge Janow issued his order which, for the first time, gave legal custody of Shamema to Charles and Shelby Roberts. Up until that point, the Amherst County Department of Social Services had always been the nominal custodian. The first thing which happened after Charles and Shelby Roberts finally got custody of Shamema was that they immediately stopped all visitation, irrespective of the weekly visitation which had been ordered by Judge Janow. M. Ismail Sloan appealed. However, at the appellate level, the only judge who would agree to hear the case was Judge Gamble, who had recently been appointed. Judge Gamble was the former law partner who was a close friend of Judge Janow and a neighbor as well. He had also been the attorney for Alma Dawson who was suing M. Ismail Sloan for the "widow's share" of his father's estate. The secretary of Judge Gamble was a close personal friend of Charles and Shelby Roberts. However, in spite of all of these negative factors, M. Ismail Sloan had essentially no choice but to accept him as a judge because, by this time, all of the other judges of the entire 24th Judicial Circuit had disqualified themselves from this case, and no other judge could be easily found in Virginia who was willing to take it.

267. As soon as Judge Gamble got this case, he lapsed into the same pattern as his friend Judge Janow, conducting long hearings with long adjournments, with no final appealable order entered. During this time, M. Ismail Sloan had no visits with his daughter. Finally, Richard L. Groff agreed to try to set up one last visit, even though the Amherst County Department of Social Services was officially no longer connected with this case. That visit was scheduled for September 4, 1991 and was the first time that Shamema and her father had seen each other in seven weeks. They went out the back door together and were intercepted by Richard Groff, who called the police. The police came and arrested M. Ismail Sloan, putting him in jail for 18 days, During this 18 days, he was indicted by Judge Harris for the felony of interstate kidnapping even though he and Shamema had never left the back yard of his house. Immediately thereafter, Judge Gamble ordered that Charles and Shelby Roberts would have full custody of Shamema with no right of visitation whatever by either of her parents. Judge Gamble dropped the previously imposed restriction that nobody could take the child out of state. In effect, he gave Charles Roberts full parental rights, Even then, he still refused to enter a final written appealable order, waiting until M. Ismail Sloan had been summoned out to California in connection with the Jessica case. He then secretly entered an order and also disqualified his attorney in such a way that M. Ismail Sloan would not find out about it on time, in order to eliminate the possibility of a timely appeal. He also issued two or three more orders for the arrest of M. Ismail Sloan, one of which dated back to the September 8, 1986 case.

268. The result of all this is that the entire family of Ismail Sloan has been decimated, and there is almost no hope of recovery without intervention by a federal court. First, the 80-year-old grandmother was kidnapped. When Ismail Sloan complained to the Bangkok police about this, he was told to keep quiet about this or else he would be arrested. He did not keep quiet, and for that reason was arrested. He then went to the United Arab Emirates, where his two daughters were kidnapped and taken to Madison Heights, Virginia. When he went there to recover them, he was again arrested. While he was in jail there, his last remaining son was also kidnapped. When he went to New York to recover that son, he was told to get out of the police station or else he would be arrested. Later on, again he was arrested.

269. While all this has been going on, Ismail Sloan is not even remotely guilty of anything. He is merely an exceptionally devoted father to his children and a devoted son to his mother. In fact, he is not the villain but the victim. His mother was kidnapped, not to help her but to get her money. Now, she is alone in a nursing home, where she doesn't want to be. Meanwhile, her other son, Creighton, with whom she has been on bad terms for many years, has once again started directing her social security and pension checks into his own bank account. It was for precisely this reason that she ran away from him in the first place.

270. While all of the three children are completely devoted to their father, he is not allowed to contact them. Again, this is not for their benefit, but rather for the benefit of those people who have kidnapped them. Charles Roberts wants to adopt Shamema as his own daughter. Defendant Frank Davidson III wants to adopt Jessica as his daughter. All these people want the children of Ismail Sloan, not because there is something wrong with them, but because everything is right with them. All of these children are attractive, healthy, happy and extremely bright. These defendants are unable to produce children of their own of this high quality, so they want to steal the children of Ismail Sloan.

271. It is submitted that all these hearings are illegal and without jurisdiction. Under the Federal Parental Kidnapping Prevention Act, 28 U.S.C. 1738A, a custody hearing cannot be held until the child has been resident in the state for six months. Two children arrived in Virginia on October 9, 1990 and the last one came on November 12, 1990 which is much less than six months before custody petitions were filed regarding them. For this and other reasons previously stated, all of these state court custody proceedings should be enjoined by this court. Similarly, the proceedings before Judge Roe regarding Helen Marjorie Sloan went forwarded only because Helen Marjorie Sloan was kidnapped and brought to South Carolina by force. These proceedings should be enjoined as well. A writ of habeas corpus should be issued and the grandmother and all of the three children should be produced in this court. This will enable the entire family to be reunited for the first time since these kidnappings started. An order should also be issued enjoining the defendants from any further arrests of the plaintiff for any matters pertaining to this case, so that he will be allowed freely to prosecute the legal proceedings necessary to obtain recovery of his kidnapped mother and his kidnapped children.

COUNT II

272. Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 252 of this complaint.

273. This action is brought under the Federal Kidnapping Act, 18 U.S.C. 1201, and the Federal Hostage Taking Act, 18 U.S.C. 1203.

274. The aforementioned kidnappings took place within the "special aircraft jurisdiction of the United States" under 18 U.S.C. 1201. Helen Marjorie Sloan was kidnapped onto a Northwest Airlines flight to the United States, with only a stopover or a change of aircraft in Tokyo. The two daughters were kidnapped onto a flight connecting with TWA, again with only stopovers in Bahrain and London. All of the kidnapped persons are American citizens. The kidnappings were quasi-governmental in nature. Helen Marjorie Sloan was kidnapped so that the Lynchburg Circuit Court would have jurisdiction over her. Shamema and Jessica Sloan were kidnapped to bring them within the jurisdiction of the Amherst County J & D Court. These courts proceeded forward with these cases, in a clear absence of all jurisdiction to do so. The only reason why Ismail Sloan cannot get his children back is because of these court cases. Charles and Shelby Roberts have no natural right to these children. They are able to hold Shamema by force only because of the orders corruptly signed by Judge Janow and Judge Gamble.

275. Because of the governmental involvement, it is possible that these kidnappings can be classified instead as illegal extraditions. Had it not been for the overt actions of State Department personnel, these kidnappings would not have been possible. In particular, Defendant Stephen R. Pattison caused the Sloan family to be stranded in Bangkok, and then issued illegally a passport to Boonchoo to enable Helen Marjorie Sloan to be smuggled back to America. Helen Marjorie Sloan was not guilty of any crime. She had left America to get away from her son, Creighton W. Sloan, who, according to her, had been stealing her money and depriving her of the right to live according to her own wishes.

276. This court has jurisdiction over the subject matter of these kidnappings, even though they occurred outside of the United States, because the victims were thereafter brought directly to the United States. (See <+#>United States v. De La Rosa<-#>, 911 F.2d 985 (5th Cir. 1990).)

277. Because these kidnappings occurred within the "special aircraft jurisdiction of the United States," as set forth in 18 U.S.C. 1201 (a) (3), a federal crime occurred the moment the victims were put on the airplane and even before the aircraft left the ground. Thus, a federal crime occurred at Don Muang International Airport in Bangkok when Boonchoo put Helen Marjorie Sloan on the airplane there, and a federal crime occurred in Abu Dhabi when Shamema and Jessica Sloan were put on the aircraft there. Even if, arguably, the Amherst County Department of Social Services had custody of Shamema in Virginia, it clearly did not have legal custody in Abu Dhabi. Therefore, when Shamema was taken from her father by a non-parent, a federal crime occurred. Charles Roberts and Jay Roberts are guilty of this federal crime, because they sent the airplane tickets and therefore induced or procured or caused the crime under 18 U.S.C. 2. Also, Charles and Shelby Roberts and Creighton Sloan hired Boonchoo, a criminal extortionist, and the kidnappings occurred because of the actions and the threats made by Boonchoo. This also makes Charles Roberts, Shelby Roberts and Creighton Sloan guilty under 18 U.S.C. 2. The plaintiffs are entitled to recover money damages arising from these kidnappings. (See <+#>Jaffe v. Boyles<-#>, 616 F. Supp. 1371 (D.C.N.Y. 1985)).

COUNT III

278. Plaintiffs repeat and reallege each and every allegation of paragraphs 1 through 277 of this complaint.

279. This count is based upon the Parental Kidnapping Prevention Act, 28 U.S.C. 1738A.

280. Plaintiffs demand an order awarding custody of all three children to Ismail Sloan. This court has jurisdiction to award such custody because this involves an international custody case. (See <+#>Meade vs. Meade<-#>, 812 F.2d 1473 (4th Cir. 1987)). The courts should not entertain any custody petition filed by Charles and Shelby Roberts because they are not parents or relatives of any kind of the subject child. The only contact which Shelby Roberts ever had with this child, prior to the kidnapping, arose because Shelby Roberts had been hired as a baby-sitter to care for the child. Shelby Roberts was well paid up to date for her services. Thus, she lacks any standing to sue for custody. As a result, Ismail Sloan must be awarded custody of Shamema, because no other relative has ever petitioned for custody.

281. In the alternative, the plaintiffs, including the grandmother, should be allowed to return from whence they came, without being further molested or harassed by the defendants, should they chose to do so. (See <+#>United States v. Caro-Quintero<-#>, 745 F.Supp. 599 (C.D. Cal. 1990).

282. Presumably, Charles and Shelby Roberts are claiming that they have standing to sue for custody under Section 20-125 of the Virginia Code, which parallels the federal law, and defines a "person acting as a parent" as a person "who has physical custody of a child and who ... claims a right to custody." However, this contention is without merit. Assuming that her employment as a baby sitter constitutes "having physical custody", Shelby Roberts did not make any claim for custody during the period in which she was employed as a baby sitter. The first time that she claimed custody by filing a custody petition did not occur until August 27, 1986, which was after she had already been fired from her job as a baby sitter and Shamema was no longer in the State of Virginia. Consequently, there was never a time in which Shelby Roberts both had physical custody and was claiming the right to legal custody.

283. If this court accepts the construction which will be urged upon it by Charles and Shelby Roberts, then international kidnappings of small children will become perfectly legal in America. Anyone will be able to go to a foreign country, grab a child, bring it back in America, and claim the right to sue for the custody of that child as a "person who claims a right to custody."

COUNT IV

284. Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 283 of this complaint.

285. Plaintiffs seek not only injunctive relief but actual money damages against the state court judges named as defendants in this case under 42 U.S.C. 1983. Judge Janow, Judge Richard S. Miller, Judge Gamble, Judge Harris and Judge Roe acted in clear absence of all jurisdiction in the cases before them.

286. Regarding this, Judge Janow and Judge Miller both continued to make decisions and enter orders harmful to the legal rights of the defendants even after Helen Marjorie Sloan had filed a suit against both of these judges on November 30, 1989 for doing exactly this. Judge Miller withheld the funds necessary to pay the hospital and medical expenses of Helen Marjorie Sloan for a periods of six weeks, solely to give the defendants enough time to arrange the kidnapping of Helen Marjorie Sloan. Helen Marjorie Sloan could easily have died because of the illegal acts of Judge Miller. He had no jurisdiction to act or not to act because Helen Marjorie Sloan was not a party to any case before him, had never been served with any form of process, and was outside the United States for the entire period from when the case started until the time of her kidnapping. Judge Harris indicted Ismail Sloan on the felony crime of interstate kidnapping, even though the child had never left the state, except when taken out of state by Charles Roberts.

287. Similarly, Judge Janow has entertained a custody petition dated October 19, 1990 and has deprived Ismail Sloan of his constitutionally guaranteed right to have contact with his children, in a clear absence of all jurisdiction to do so, and has ordered the arrest of Ismail Sloan, also in a clear absence of all jurisdiction to do so.

288. In addition, Defendant Judge Janow on or after October 24, 1990 ordered the withdrawal of Stephen Martin as counsel of record for Ismail Sloan, without any notice whatever being given to Ismail Sloan that his counsel wanted to withdraw. This left Ismail Sloan without legal representation at a time when Judge Janow was intending to have Ismail Sloan arrested as soon as he came to Amherst County to attempt to recover his children. This withdrawal of counsel took place over the objections of Ed Meeks, the Amherst County Commonwealth Attorney.

289. Stephen Martin had been counsel of record for Ismail Sloan since early 1986. He was the only attorney appearing during the early phases of this case. (Frank Davidson III did not appear until August, 1986). Thus, he was the only attorney familiar with the facts of this case.

290. Judge Janow wanted Stephen Martin withdrawn as counsel, because that would leave Judge Janow personally as the only person with any recollection of the facts of this case. Then, Judge Janow would be free to put Ismail Sloan in jail for one full year, as he intended to do, and nobody would be able to dispute Judge Janow's version of the facts of this case. There was no court reporter present at any of the hearings of this case so everything depends on the personal recollections and interpretations of what took place. This matter is particularly critical because all of the orders of Judge Janow were ambiguously worded and could be interpreted in different ways by different people at different times.

291. As a result of the above, Judge Janow has been involved in a plan or conspiracy with Defendants Charles Roberts, Shelby Roberts, Frank Davidson III, Linda S. Groome, Barbara J. Gaden and other defendants to put Ismail Sloan in jail without due process of law and to capture his children, in violation of the constitutional rights of all of the plaintiffs.

COUNT V

292. Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 291 of this complaint.

293. The Amherst County of Department of Social Services and defendants Virginia Burks and James Oliver, it's directors, and Rick Groff, the case worker, have deprived plaintiffs Ismail Sloan and Shamema Sloan of the right of access to his each other and have not even allowed them to speak to each other on the telephone in violation of their statutory and constitutional rights.

294. In such a case, the Amherst County Department of Social Services is required by Virginia State and federal social services law to return Shamema Sloan as soon as possible "to the parents". Ismail Sloan was the only parent of Shamema Sloan in the State of Virginia and, for that reason, the Amherst County Department of Social Services was required by law to hand Shamema Sloan over to him. (The mother of Shamema Sloan was in Chitral, Pakistan.)

295. Instead of doing what they are required to do by law, the Amherst County Department of Social Services allowed Charles and Shelby Roberts to keep Shamema Sloan in their house on 420 Amelon Road in Madison Heights, Virginia, knowing that Shamema Sloan got there as a result of being kidnapped from the United Arab Emirates by defendants to this case.

296. Shamema Sloan has never been shown to be an abused, neglected or abandoned child. To the contrary, she was perfectly all right, until she was kidnapped by these defendants. There has been heavy cable traffic through the Department of State about Shamema Sloan over the past six years. Shamema Sloan has been observed and even interviewed by State Department officials on innumerable occasions. On each and every occasion, the report back to Washington was that Shamema Sloan was healthy, happy, bright, gifted, doing well in school and so on.

297. In July, 1990, Defendant Stephen R. Pattison contrived to have the Sloan family stranded in Thailand so that they could not leave the country, first for one reason and then another. These illegal and criminal acts on the part of Stephen R. Pattison were calculated to assist the defendants in their desire to have the various plaintiffs kidnapped. This eventually led to the kidnapping of Shamema Sloan.

298. Defendants Virginia Burks, James Oliver, William H. Petty, Barbara J. Gaden and Rick Groff know that there is a warrant outstanding for the arrest of Charles Roberts on a charge of kidnapping Shamema Sloan. In addition, the Government of the United Arab Emirates has officially protested to the Government of the United States regarding this kidnapping. Nevertheless, these defendants are still allowing Charles Roberts to keep Shamema Sloan in his home.

299. Charles Roberts has been attempting to murder Plaintiff Ismail Sloan. Charles Roberts is keeping an arsenal of weapons in his house, including three loaded guns at the door or in the children's play room at all times. Charles Roberts says that he is keeping these weapons there for the purpose of killing Ismail Sloan should he try to see his children. Shelby Roberts testified that she carries a 357 Magnum handgun in her purse at all times, for the purpose of killing M. Ismail Sloan. That have also trained Shamema Honzagool Sloan in how to use a handgun, and have told Shamema Honzagool Sloan that she should shoot and kill her own father should he try to recover her. Charles Roberts and his two sons have also been to the house of Ismail Sloan at 917 Old Trent's Ferry Road in Lynchburg, looking for him there.

300. Defendants Virginia Burks, James Oliver and Rick Groff know that Charles Roberts has the plan and intention of killing Ismail Sloan and still they allowed two of the daughters of Ismail Sloan to be kept in the house of Charles Roberts.

301. The Virginia State and federal taxpayers were required to finance all this because Charles and Shelby Roberts were appointed as "foster parents" by the Amherst Country Department of Social Services and received foster care money since the day of October 24, 1990, when Judge Janow first heard their custody petition. Charles and Shelby Roberts had no experience in this and had never previously been appointed as foster parents. They were appointed as foster parents on this occasion solely because it was known that Charles and Shelby Roberts wanted to adopt Shamema Sloan as their own child and, for this reason, had kidnapped Shamema Sloan from the United Arab Emirates.

302. Both of the parents of Shamema Sloan are Muslims. Shamema Sloan has been raised in the Muslim religion, reads and recites the Holy Koran and prays in the mosque. She is a fluent reader of the Arabic language. She speaks fluently several languages, including Arabic and Singhala. Charles and Shelby Roberts cannot speak these languages. They become upset when they hear Shamema speaking these languages in their home. This has caused grave anxiety to Shamema Sloan and, as a result, she talks very little in their home or in school.

303. Charles and Shelby Roberts have refused to enroll Shamema Sloan in a normal public school. Instead, they have enrolled Shamema in a Bible oriented school which is located on the premises of their own Temple Baptist Church. Shamema Sloan is not being allowed to receive a normal secular education. She is being forcibly converted to the Christian religion, contrary to the wishes of her parents and in violation of the First Amendment rights of the plaintiffs.

304. Shamema Sloan has been ordered by Charles and Shelby Roberts to stop using the name "Sloan." She is being required to call herself "Shamema Roberts", to call Charles Roberts "Daddy" and to call Shelby Roberts "Mommy". The Roberts are attempting to erase all recollection of her past life from the memory of Shamema Sloan. They want to make her into a Christian religious fanatic like they are, depriving her of her unique cultural position. Regarding the natural mother of Shamema, Shelby Roberts testified before Judge Gamble, "Just because you were born in a garage, doesn't make you a car."

305. In this connection, it must be recalled that Shamema Sloan is actually the daughter of the royal family of the region of Pakistan where her mother comes from. She is a famous person in the country of Pakistan. On the other side of her family, her grandmother was a prominent medical doctor in the City of Lynchburg and still has a high net worth. In contrast, the Roberts are normal or below average people of the "hillbilly" type, who are known in the local area as "rednecks". They do not have the slightest notion of what in involved in raising a brilliant and gifted child like Shamema. Charles Roberts is a machinist who works as a common laborer in a factory. He has a low I.Q. Shelby Roberts is a secretary for defendant John, Stewart, Walker, who previously worked with her sister (who died at age 73) as a home care helper and sitter, which is how Ismail Sloan came to hire her as a baby sitter. The Roberts are 59 and 53 years old years old, respectively. Shelby Roberts weighs 350 pounds, has a heart condition and could die at any moment. They have no qualifications to care for a gifted child like Shamema who has been tested to be at the genius level. They are incapable of providing the rich cultural environment which Shamema needs.

306. In addition, Shelby Roberts has indicated on several occasions going back to 1986 that they have at least thought of removing Shamema to another state. They have taken Shamema to South Carolina recently. This is one of the many reasons why Ismail Sloan removed Shamema Sloan from the State of Virginia on August 25, 1986, immediately after Judge Janow awarded custody of Shamema Sloan to him. A great danger existed, especially at that time, that the Roberts, being no doubt unhappy with the decision of Judge Janow, would run away with Shamema, who was only four years old at that time.

307. All of these facts are well known to the other defendants to this action. Nevertheless, they are allowing Charles and Shelby Roberts to keep Shamema in their home at taxpayer expense and contrary to the bests interests of all of the plaintiffs, including especially Shamema.

308. The plan of the Roberts and their attorneys, Defendant Frank Davidson III and Linda S. Groome, along with Judge Janow, is to have the Roberts adopt Shamema. There are various provisions of the Virginia Code which allow the termination of the parental rights to the natural parents of any child who is in foster care. After that, the child can be adopted by the foster parents. In other words, they believe that they have found a loophole in the law which allows them to kidnap a child from a foreign country, get the child placed in their own foster care and eventually to adopt the child. However, children are not supposed to be placed in foster care unless they are abused, neglected or abandoned, none of which applies here. Thus, they are flouting or violating the actual intent of the law in order to avoid prosecution for their own criminal acts of kidnapping. All of this is being done at taxpayers expense.

COUNT VI

309. Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 290 of this complaint.

310. Defendants Creighton W. Sloan, W. Cassel Jacobson, Boonchoo, John Sobell, Stephen R. Pattison, Northwest Airlines and Killis T. Howard are all guilty of criminal involvement in the kidnapping of Helen Marjorie Sloan from her hospital bed in Bangkok. The reason for this kidnapping was that Creighton W. Sloan, Cassel Jacobson, Killis T. Howard and other defendants had been trying to seize control of the assets of Helen Marjorie Sloan and had been involved in litigation against her since 1986.

311. In spite of or because of this litigation, Helen Marjorie Sloan refused to return to the United States since 1986 and therefore could not be served with process. For that reason, the defendants were unable to confiscate her bank accounts, sell her house and take her other economic assets, as they wanted to do. Therefore, they arranged to have her kidnapped to bring her within the jurisdiction.

312. An order should be issued by this court requiring that all funds removed from her bank accounts since the date of her kidnapping should be immediately restored to those bank accounts. The defendants should also be required to refund the social security and pension checks which they have stolen from Helen Marjorie Sloan since the date of her kidnapping.

COUNT VII

313. Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 312 of this complaint.

314. This is an action brought under the Federal Tort Claims Act against defendants Stephen R. Pattison, Edin Brown, William Crawford, Marlee Anderson, Eileen F. Lewison and the United States Department of State.

315. As previously set forth above, these defendants, and most especially Defendant Stephen R. Pattison, conspired in the kidnapping of the mother and the infant children of Ismail Sloan. The master mind behind these kidnappings was Defendant Stephen R. Pattison. He caused the Sloan family to be stranded in Bangkok by refusing to issue a passport with full validity to Ismail Sloan, as a result of which Helen Marjorie Sloan became ill and had to be hospitalized. Then he failed to use his diligent efforts to obtain the money to pay the bill. The amount of $4,000 arrived at the American Embassy on August 10, 1990 to pay the bill, but Stephen R. Pattison did not obey the instructions attached to that money. Instead of using the money to pay the bill, he gave it to Creighton W. Sloan, who had not seen his mother in years and who came to Bangkok just to intercept this money because he did not want the bill to be paid. Defendant Stephen R. Pattison did not inform Helen Marjorie Sloan or Ismail Sloan about any of this. They did not even know that Creighton W. Sloan had come to Bangkok and taken money belonging to Helen Marjorie Sloan until two weeks later. Stephen R. Pattison kept concealed from the plaintiffs what was going on behind their backs. They had no way of realizing the danger they were in until it was too late.

316. After that, Stephen R. Pattison issued a replacement passport to Boonchoo to help Boonchoo smuggle Helen Marjorie Sloan out of Thailand and separate her from her son and her grandchildren against her wishes. He did this knowing that Ismail Sloan held the original passport. After that, Defendant Stephen R. Pattison contrived to have Ismail Sloan arrested on frivolous charges and tried to kidnap the three infant children of Ismail Sloan. The only reason that Defendant Stephen R. Pattison did not succeed in kidnapping the children was that Ismail Sloan paid a bribe to have himself and his family members smuggled across the border into Malaysia.

WHEREFORE, for all of the reasons set forth above, the plaintiffs are entitled to all the relief heretofore mentioned, including especially the following:

1. A writ of habeas corpus requiring the production of Helen Marjorie Sloan, Shamema Sloan, Jessica Sloan, Michael Sloan, George Sloan and Anusha Sloan in this honorable court.

2. An order enjoining all state court proceedings related to this suit. In particular, an order should be entered enjoining Defendants Judge Janow and Judge Gamble from proceeding on custody petitions which have been filed for the custody of Shamema Sloan and Jessica Sloan. These children should be returned to their parent or parents forthwith. In addition, the proceedings before Judge Roe and Judge Miller regarding the bank account and other assets of Helen Marjorie Sloan should be enjoined.

3. An order enjoining Defendants William H. Petty, Judge Gamble, Judge Janow and Michael W. Cox, the Amherst County Sheriff, as well as the Lynchburg Police Officers, from further arrests of Plaintiff Ismail Sloan for any matter pertaining to this suit. Ismail Sloan should be allowed to proceed with his legitimate efforts to recover his kidnapped children without any threats of arrest or other forms of harassment on the part of these defendants.

4. An order restoring all of the funds of Helen Marjorie Sloan and M. Ismail Sloan to their bank accounts, a temporarily freeze on the assets of Helen Marjorie Sloan pending further orders of this court and an order enjoining the sale of her house.

5. An order of custody, awarding the custody of Shamema Sloan, Michael Sloan and Jessica Sloan to the father, Ismail Sloan, and allowing him to take them back to the place from which they were kidnapped, should he chose to do so.

6. An order enjoining Charles Roberts, Shelby Roberts, Jay Roberts, and Larry Roberts from any form of contact with Shamema Sloan, Jessica Sloan or Michael Sloan.

7. A judgment in favor of the plaintiffs against all of the defendants in the amount of one hundred million dollars, ($100,000,000) plus costs, interest and sheriffs fees, representing actual, punitive and exemplary damages.

8. That this action be tried by jury.

______________________

M. Ismail Sloan

50 Broad St., Suite 2266

New York, NY 10004

Sworn to before me this _____

day of May, 1992

________________________

NOTARY PUBLIC

• Opinion of US Magistrate Judge Go in the above lawsuit against Stephen R. Pattison
• Khalid Sheikh Mohammed: Do you know this man? I do!
• Reply of Mansoor Ijaz
• Charles Roberts tried to have Shamema Kidnapped in Colombo, Sri Lanka
• Wanted for Kidnapping
• Shamema Joins the Marines
• The Bangkok Nation article
• Lawrence of Arabia and Chitral
• Letter to Amin-ur-Rehman
• The Story of Poor, Little Honzagool
• Honzagool being Prepared for Marriage to Me
• Honzagool
• The Family of Honzagool
• Letter about Honzagool
• Reasons why Honzagool is still legally my wife and all those other kids are bastards
• Shamema, the daughter who was kidnapped from Honzagool
• Charles Roberts, kidnapper of Shamema, the Daughter of Honzagool
• The Snow Leopard, once believed to be extinct and last seen in Chitral, is making a comeback
• Pakistan Drops the Bomb
• Nuristan: Hidden Land of the Hindu Kush