September 29, 1986
Dear Mr. Gamble,
In the latter part of 1985, I retained you as my attorney to represent me in connection with a custody petition which I planned to file regarding my daughter, Shamema Sloan. After you had accepted a retainer check from me, I spent several hours with you in a meeting during which I revealed to you every material fact regarding that situation. I also handed over to you a box of sensitive documents pertaining to this case. Prior to doing so, I had carefully explained that this matter was to be taken by you in strictest confidence and that utmost secrecy was required, in addition to the normal attorney-client confidentiality. Previously, I had declined to discuss the facts of the case with you in detail until you had agreed to accept me as your client.
A few days after our meeting, you returned the retainer fee I had paid you in the mail, along with a letter explaining that you had discovered that a secretary in your office was a personal friend of Mrs. Shelby Roberts, who was employed by me to take care of my daughter, Shamema, and that therefore my custody petition might create a conflict of interest in your office. While I failed to follow the logic of your letter, I naturally accepted your decision to decline to represent me and assumed that nevertheless you would retain the confidentiality of the delicate information I had given you regarding my daughter.
I was somewhat surprised when, during the first week of January, 1986, I was contacted by one Alma Dawson, who claimed that she had just married my ailing father in the Emergency Room of the Lynchburg General Hospital, and who stated that your law partner, Donald Pendleton, was her lawyer. She further stated that she was going to authorize Mr. Pendleton to file a variety of civil and criminal proceedings in an effort to locate and recover my father's assets. I was even more concerned when, just three days after my father's subsequent death on January 19, 1986, I received a letter from your law firm stating that your firm would represent Ms. Dawson in proceedings to recover the "widow's share" of my father's estate. It seemed apparent to me that if your firm had a conflict of interest in representing me in a custody proceeding involving my daughter, Shamema, then that same conflict of interest would preclude you from representing a legal adversary who was trying to secure a portion of my father's estate in which my daughter has an indirect interest, through me.
Now, the situation has become considerably more serious. Apparently, your office has become a central coordinating point for new litigation brought by various attorneys. The information which I originally gave you in strictest confidence, has been freely distributed to those attorneys starting with, of course, your own law partner. As a result, I have been hit with litigation instituted by four separate attorneys, all of whom are making direct or indirect use of the information which I gave you. These attorneys are: Royston Jester, Mr. Frank Davidson III, Walter Anderocci and Donald Pendleton.
It is true that a secretary in your office knew that a Mrs. Roberts in Amherst County was taking care of a young girl named Shamema, even before I contacted your office. However, I a sure that neither your secretary nor hardly anyone else in Amherst County knew that I was the father of Shamema, or what her real last name was, or who her mother was, or any of the other background of this unusual situation. In short, nobody knew that I had been forced to hide Shamema with Mrs. Roberts because of death threats and kidnapping threats I had received from Black Muslims and Pakistani groups and individuals connected with my ex-wife Anda (who is not the mother of Shamema), in New York. I am also sure that Mrs. Roberts, who had been well informed of the good reasons I had for keeping my daughter with her, had maintained the security of Shamema up until that point and that nobody outside of the Roberts family and my family knew the reasons for which strict secrecy had to be maintained regarding the whereabouts of my daughter.
I have now learned that sometime in June or July, 1986, your office contacted by one Walter Anderocci, Anda's lawyer in New York, and that your law partner, Don Pendleton, provided Mr. Anderocci with the name address and telephone number of Mrs. Roberts. Since then, Anda has been in direct telephone contact with a member of the Roberts family.
As you know, because I explained the situation carefully to you in your office, Anda is the very person who has been directly or indirectly responsible for the death threats against me and the kidnapping threats against my daughter, all of which has been the subject of an F.B.I. investigation. Anda has been trying for the last four years to have my daughter by force taken away from me and sent to Pakistan. Providing information about the identity and whereabouts of Shamema and Mrs. Roberts to Anda's attorney was a gross violation of your law firm's ethical responsibilities.
I found out that my daughter's security had been compromised on or about August 7, 1986 and was forced to remove Shamema permanently from the Roberts' home as quickly as I could possibly could without major adverse effects on Shamema, which I did on August 25, 1986.
Your severe breech of your ethical duties has caused severe adverse consequences for me, my daughter, my mother and my entire family, not to mention the Roberts and other affected persons. All of this was an outgrowth of the decision by your firm to represent Mrs. Dawson in her misguided litigation against me and my family in a situation where a conflict of interest was involved.
Incidentally, I have learned that your representation of Mrs. Dawson in her efforts to obtain control of my father's assets commenced even prior to January, 1986. I have been told that on December 30, 1985, Ms. Dawson approached my father with a bunch of legal documents, presumably prepared by your law firm, and asked for his signature. These documents would have turned over all of my father's assets and estate to Mrs. Dawson. My father refused to sign the documents and suffered a major seizure requiring hospitalization the same day. It was also acting on your firm's advice that Mrs. Dawson undertook to marry my father at a time when he was obviously near the end of his life in order to get a "widow's share" of his estate. In short, had it not been for the unethical conduct by your law firm, it seems possible that my father would still be alive today.
It goes without saying that your law firm should be disqualified from appearing further in any litigation against me. I also believe that those lawyers who have received tainted information (tainted by your breech of attorney-client confidentiality) should similarly be disqualified. Naturally, I intend to hold you and your firm legally responsible for your wrongful conduct.
Very Truly Yours,
Samuel H. Sloan
cc: Frank Davidson III
Royston Jester, IV
Ed Meeks, Amherst Commonwealth Attorney
Bill Petty, Lynchburg Commonwealth Attorney
Judge Larry Janow
Judge Kristin Booth Glen