This is a petition for a rehearing and rehearing en banc from the decision of this court dated November 14, 1996, which dismissed this appeal. First, I need to quote this court's prior order, dated August 8, 1996:
"On preliminary examination, the Court concludes that neither a transcript nor statement of facts was timely filed in this case, see Rule 5A:8, and that no extension of time in which to file a transcript or statement of facts is now possible, Jordan v. Price, 3 Va. App. 672, 353 S.E.2d 168 (1987). While an absence or a statement of facts does not always deprive this court of jurisdiction, the court will consider only those issues which may be decided without reference to a transcript or statement of facts. "When a transcript is indispensable to the determination of an issue, the absence thereof in the record is a jurisdictional defect and required dismissal of the claim." Goodpasture v. Goodpasture, 7 Va. App. 55. 57, 371 S.E.2d 845, 846 (1988) (family law case saved from dismissal by judge's letter opinion, other documents). E.g., Anderson v. Commonwealth, 13 Va. App. 506, 413 S.E.2d 75 (1992) (statement of facts in criminal case); Turner v. Commonwealth, 2 Va. App. 96, 341 S.E.2d 400, (1986) (transcript in criminal case) ; Barrett v. Barrett, 1 Va. App. 378, 380, 339 S.E.2d 208, 210 (1986) (neither filed).
"Accordingly, it is ordered that the appellant shall show cause, by reply to this order on or before August 13, 1986, why this appeal should not be dismissed. In any response to this order appellant shall state clearly any questions properly presented by this appeal, see Rules 5A:12 (c) and 5A:20 (c) and preserved for appellate review, see Rule 5A:18, which can be considered without resort to the transcript or statement of facts. Appellant shall further explain why the questions can be considered without reference to the transcript or statement of facts. The period for filing pleadings shall not be enlarged by this order."
As this court correctly notes, the issues I have raised on appeal and in a prior response to an order to show cause, are the following:
1. Whether the courts of Virginia have jurisdiction over this entire matter.
2. Whether third parties who are in no way blood relatives or family members of a child have standing to sure for the custody of a child on the basis of having served as foster parent for less than ten months.
3. Whether the courts of the Commonwealth of Virginia can deprive a parent of the custody of a child solely on the grounds of objections made by third parties to the life style and religion of the natural parents.
All of these questions are jurisdictional in nature. The Appellant submits and has contended during the entire ten years that this case has been pending before the courts of Virginia that Virginia does not now and has never had jurisdiction over this matter. There are innumerable reasons for this. When the Roberts filed their first petition on August 27, 1986, the summons and complaint were never served for the simple reason that neither the parents nor the child were in the Commonwealth of Virginia at the time. Thus, the Amherst County J & D court neither had personal jurisdiction over this case nor rem jurisdiction over the case.
Furthermore, nowhere in the statutes and laws of Virginia is there jurisdiction for a Virginia Juvenile and Domestic Court to hear a case such as this one. Charles and Shelby Roberts are not parents of the child or in any way relatives of the child. Moreover, at the time they filed suit, they were not grandparents, step parents or foster parents and indeed they had no connection with the child whatever, other that the fact that Shelby Roberts had previously been employed by the appellant as a baby sitter to care for the child.
After four years of constant effort, Charles and Shelby Roberts succeeded in having the child kidnapped in Fujairah, United Arab Emirates on October 7, 1990. They brought the child, who was eight years old at the time, to their home in Madison Heights, Virginia. They then told the Amherst County Department of Social Services that this child had been abandoned and that they wanted to be appointed as foster parents. They were appointed as foster parents on October 12, 1990. Two weeks later, on October 23, 1990, they filed their second petition for the custody of this child.
By law, these petitions were absolutely without jurisdiction, for a large number of reasons. The J & D Court was required to dismiss these petitions immediately. Under no circumstances should the natural parents have been put under long and tortuous proceedings which now have lasted more than six years since the child was kidnapped. The Virginia J & D Courts are courts of limited jurisdiction. Only certain specifically delineated kinds of cases can be heard by a J & D judge, and this is not one of them. Moreover, upon appeal from an order of the J & D Court to a circuit court, the circuit court only has the same limited jurisdiction that the J & D Court had. Martin v. Pittsylvania County Department of Social Services, 3 Va. App. 15, 348 S.E.2d 13, 18 (1986), Lowe v. Grasty, 203 Va. 15, 122 S.E.2d 867 (1961).
The respondents have never cited any provision of the Code of Virginia which gave Judge Janow jurisdiction to hear this case and indeed there is none. Judge Janow himself said that he was relying on "the inherent power of the court" to confer custody on the Roberts. However, the Virginia State Legislature has disagreed. The law of Virginia, as passed by the State Legislature, clearly provides that foster parents cannot file a petition for the custody of a child until after they had been foster parents for one year. Stanley v. Fairfax County Department of Social Services, 395 SE2d 199, 207, 10 Va. App. 596 (1990). However, here, the Roberts got themselves appointed as foster parents (and only by falsely claiming that the child had been abandoned whereas they later said that they had spent $40,000 to have the child kidnapped and brought to America) on October 12, 1990, and they filed for custody on October 23, 1990, only 11 days later.
All this is apparent from the records and the pleadings of this case. Unfortunately, Judge Janow has arrogantly and contumaceously refused to allow his clerk to transmit the entire record on this appeal. Only a brief skeletal record has been transmitted from the J & D court. Nevertheless, this court has the power simply to call and ask that the complete record and sent up and indeed I have repeatedly asked that it do so.
The three issues which I raise in my opening brief on this appeal all go to these jurisdictional issues. None of this depends in any way on a transcript or a statement of facts. There should have been no transcript because there should have been no hearing in the first place. The child should have been summarily returned to the natural parents, the course favored and recommended by the Amherst County Department of Social Services. Judge Janow refused to follow that recommendation.
Here again, Judge Janow exceeded his jurisdiction. A J & D judge simply cannot ignore a recommendation by the Department of Social Services that a child be returned to the parents. He can return a child to the parents contrary to the recommendation of the Department of Social Services, but he cannot have a child taken away from the parents absent a request from the Department of Social Services. This court has ruled that in such a case, the judge acts without jurisdiction. Rader v. Montgomery County Department of Social Services, 5 Va. App. 523, 526, 365 S.E.2d 234, 236 (1988). No allegation of abuse, abandonment or neglect has ever been made by anyone regarding this child, other that the self serving and unverifiable allegations made by the Roberts. It violates the statutory scheme to allow a Department of Social Services proceeding to go forward solely to enable unrelated third parties to seek the custody of a child. Smith v. Organization of Foster Families, 431 U.S. 816, 842 (1977).
Because of the blatant disregard by both Judge Janow and his former law partner Judge Gamble of all of the jurisdictional rules of the Virginia courts, it is obvious what is really going on. These judges know that they are breaking the rules but they also know how difficult and indeed nearly impossible it is to appeal in Virginia. I have been filing these appeals since February, 1991. This is around the 15th or the 16th time that one of my appeals has been dismissed. I have appealed in several other states and never had any problem perfecting an appeal. I even won a fully argued case in the United States Supreme Court. However, Virginia refuses to allow even one of my appeals to go thgrough. Charles and Shelby Roberts have also had me arrested ten times, even though they are the criminals and not I. By bringing a multiplicity of false and fraudulent complaints, they finally had me convicted and sentenced to five years in prison, of which I served about 19 months. They keep trying to have me arrested again and again. Shelby Roberts once testified, "I will do anything to have Sam thrown back in the pokey."
The fact is that the actual criminals are also Judge Janow and Judge Gamble. They both personally participated in the conspiracy to kidnap this child. Judge Gamble was not yet a judge. He was in private practice and had filed a lawsuit against me. After he got himself appointed as a judge, he insisted that all cases against me, including the case which his own law firm had filed, be assigned to him personally.
By repeatedly dismissing my appeals without any valid reason or excuse, the judges of this court make themselves co-conspirators to the kidnapping of this child. It is to be pointed out that this is a type of case where I by statute have a mandatory right to appeal. The two cases cried in this decision of this court dated November 14, 1996 are not this type of case. Those are both criminal cases, where an appeal is discretionary. Anderson v. Commonwealth, 13 Va. App. 506, 413 S.E. 2d 75 (1992); Turner v. Commonwealth, 2 Va. App. 96, 341 S.E. 2d 400 (1986).
The reason that this court cannot find any precedent for dismissing my appeal is that there is none. I have researched the law in all 50 states. In no case in any of those states in any of the last 200 years has a case happened like this one. In no case has custody been taken from natural parents and given to complete outsiders. Always there has been some prior family relationship with the child, such as a step-parent or foster parents. Here, the Roberts have had no such relationship. They simply kidnapped the child. However, they knew that because of the participation of Judge Janow in the kidnapping that he would award them custody once they got the child. I knew that as well and for that reason when I arrived in Virginia on November 13, 1990 to try to recover my kidnapped daughter, one of the first things I did that day was to demand the disqualification of Judge Janow from this case. Judge Janow refused to disqualify himself for the simple reason that he is guilty of this crime and he might as well turn himself into the police if he is not the judge hearing this case. I filed a complaint against Judge Janow with Reno Harp of the Virginia Judicial Inquiry and Review Commission in February 1991, but he refused to consider my complaint and returned it the next day. I filed lawsuits against Judge Janow and he filed a lawsuit against me. Judge Janow won a $4,806.28 money judgment against me in November 1991. It was because of his efforts to enforce this money judgment plus a judgment which Charles and Shelby Roberts had obtained for the costs and expenses in kidnapping my daughter that I was forced to file for bankruptcy in 1994, naming both Judge Janow and Judge Gamble as creditors in my creditors list. Nevertheless, Judge Janow continues to be the judge on this case and to insist that he has exclusive jurisdiction over this matter. It is obvious that he knows that he dare not give up control over this case because no other judge in Virginia would decide the case the way that he has done.
Furthermore, Judge Janow had no jurisdiction for another reason. The Supreme Court of New York State had already awarded custody of this child to the mother and then to me. It is true that Judge Janow apparently did write a letter to a judge in New York in 1986, but that was not the judge who had decided this case. Moreover, there was no follow up and no order entered either in Virginia or in New York transferring the case from New York to Virginia. Moreover, Judge Janow did not disclose in his letter to the New York judge that the contestant in Virginia was not the natural parents of the child but rather Charles and Shelby Roberts who would not have been allowed under New York law to file a case for the custody of this child there. Alison D. v. Virginia M, 77 N.Y.2d 651, 586 N.Y.S.2d 586 (Ct.App. 1991)
Here is the decision and order of Judge Lauren Backal of the Supreme Court of New York State:
"Upon the foregoing papers this motion for an order modifying the child custody provisions of an order of this court dated June 7, 1982 that awarded custody of the parties infant issue, Shamema Honzagool Sloan, date of birth October 15, 1981, to the defendant - mother, Honzagool, is granted on default. Pursuant to the June 7, 1982 order, defendant - mother was granted custody of the infant issue provided she remain with the child in the State of New York. On or about October 1, 1982, defendant-mother abandoned plaintiff-father, M. Ismail Sloan, and the infant issue in the United States and returned to her native Pakistan. To date, defendant -mother has not returned to the United States. Plaintiff father has been the de facto custodial parent of the infant issue since the time of defendant - mother's departure and has provided the child with a caring and stable home for the past twelve years. Accordingly, it is in the child's best interest that the custody order of this court be modified to the extent of awarding custody of the infant issue, Shamema Honzagool Sloan, to the plaintiff - father, M. Ismail Sloan
"This shall constitute the decision and order of the court.
"Dated: October 25, 1994
/s/ L. Backal
Lorraine Backal, A. J. S. C."
Please note that this decision relates back to a prior decision dated June 7, 1982, which was years before the Roberts ever filed a petition for the custody of this child.
Here is the pertinent part of that prior decision, which was by Judge Anthony Mercorella:
"It is hereby:
"ORDERED AND ADJUDGED that the custody of Shamema Honzagool Sloan be and the same hereby is awarded to her mother, Honzagool, at least during her formative years while of tender age provided respondent Honzagool remains together with the child in the State of New York and it is further
"ORDERED AND ADJUDGED that this court may modify, alter or change this order, by the making of such further provision or provisions with respect to the custody of such child as it may at any time in the future deem necessary or proper and it is further
"ORDERED AND ADJUDGED that the petitioner is granted leave to apply for a change in custody should the circumstances warrant.
"J. S. C.
Thus, it is clear that if the Roberts wanted to apply for custody, they had to appear in the courts of New York State. They could not simply kidnap the child, take her to Virginia, and apply for custody there before a judge known to be sympathetic to their cause, as they have done. However, the Roberts obviously could not go to New York to appear in this case because they would be arrested for kidnapping there. There are indeed warrants outstanding for the arrest of Charles Roberts for the kidnapping of my daughter. The Roberts are well aware of that, so they have not ventured outside the Commonwealth of Virginia much at all lately.
Shortly after the decision of Judge Backal above, she retired. She was already ill and out sick on the first date this case came before her. I have since been in touch with her law clerk, who now works for a New York State assemblyman, and he states that Judge Backal is fully aware of the present situation, which is that Virginia is ignoring her order and the Roberts still have my daughter, and that she still adheres to her decision.
Nevertheless, because of the untimely retirement of Judge Backal, I have not been able to secure the arrest of Charles and Shelby Roberts for extradition to New York on a charge of kidnapping my daughter.
I am sure that the judges of this court have a lot of experience in dealing with hard core criminals. A truly hard core criminal will always come up with a justification or excuse for any act he commits regardless of how heinous or monstrous the criminal act might be. The victim deserved it or everyone else does it or whatever might be the explanation for committing the crime. There is never any sign of remorse or unhappiness except possibly unhappiness at having been caught.
Similarly, in Charles and Shelby Roberts and Judge Lawrence Janow, we are dealing with three of the most monstrous and heinous criminals imaginable. Like the typical hard core killer, they keep coming up with excuses for what they have done. This can been seen in the response they have filed in this court. Anybody can see that they are completely guilty. Yet they maintain that they were justified in taking this child.
As to the reasons why I did not file a transcript or a statement of facts, I have already explained this but will explain it again. On the same day as the hearing in the Amherst Circuit Court, I contacted Court Reporter Terri Spruce. She said that she would do the transcript but it would take six weeks for her to get started because she was just recovering from major surgery. I also called every other court reporter in the area and they all said that only Terri Spruce could handle this case.
Starting after about six weeks, I tried calling her again. However, she did not answer her phone. I called repeatedly. I could not write her a letter because her address is not listed with directory information. Finally, I called Judge Trabue and explained the situation. He informed me that Terri Spruce was apparently back in the hospital and undergoing surgery again. He gave me the name of another court reporter in Campbell Country and suggested that I contact her. In fact, this was one of the many court reporters I had contacted earlier who had told me that she could not do this job. I contacted her again nevertheless. She is Judge Johnson's court reporter and is only there when the judge is there. I had to call her about 50 times before finally getting through to her. (This is not an exaggeration). When I finally reached her, she said that she also had health problems and went into a long story about this. She gave me the number of a court reporter in Blacksburg to try.
This process continued and in the end time ran out. As this court noted in its decision: "No extension of time in which to file a transcript or statement of facts is now possible." I know of no other state which has such a hard rule that a transcript must be filed within 60 days. For example, in California where I live, it normally takes five months before the transcript goes up. If Virginia rules were applied here, almost every appeal would be dismissed prior to hearing. Indeed, I understand that this may already be the case in Virginia.
In any event, a transcript would have shed absolutely no light whatever on this case. Charles and Shelby Roberts called no witnesses and presented no evidence. I did almost all the talking and I said nothing that I have not said in papers ad nausium. Judge Trabue said that he was not going to review the facts of the case. He was only going to hear testimony as to whether there had been any changes in the circumstances of the child. Since I have been completely denied any information regarding the health, welfare, well being, school grades, medical care or any other pertinent facts concerning my daughter, it was impossible for me to give any testimony, other than to say that the child had gotten older.
For these reasons, I strongly believe that I have the absolute legal right to have this appeal heard and that it is illegal for this court to dismiss this appeal. All three issues I have raised go to the question of the jurisdiction of the court. The complete record of this case, which is more than 1000 pages long, will show that I am correct and that Virginia has never had jurisdiction over this matter from the beginning. Accordingly, the child must be returned to me. It is simply illegal from this child to be withheld from her rightful parental custody.
It is also noteworthy that the opposing side is in default. I filed my opening brief on September 9, 1996. Their opposing brief was due 30 days later. They have filed nothing. How can we even know that the child is still alive? How can this court make a decision in such a void of information? Every fact and detail of my life is disclosed in the record. In contrast, there is no information whatever about Charles and Shelby Roberts. Although I happen to know their ages, there is nothing about even that in the records. There is nothing about their incomes or whether they are even still working (they are at retirement age). I have no way of knowing if they are still alive. I do know that they have made arrangements for other members of their religious cult to take over control of my daughter should they pass on.
The natural parents have a constitutionally protected liberty interest in the custody of their own child. Stanley v. Illinois, 405 U.S. 645 (1972). Significantly, in the 1990 and 1991 proceedings below, the Amherst County Department of Social Services called no witnesses and presented no evidence. The Department of Social Services has repeatedly stated that it would have immediately returned the child to the father, were it not for the fact that it was enjoined by an order of Judge Janow of the Amherst County Juvenile and Domestic Relations Court from allowing any contact between the child and her father. There had been no hearing and the Amherst County Juvenile and Domestic Relations Court lacked jurisdiction to enter such an order, absent a hearing and a showing of possible harm to the child. Wright v. Arlington County Department of Social Services, 388 S.E.2d 477 (1990); Santosky v. Kramer, 455 U.S. 745, 769 (1982).
No home study was ever conducted and filed with the court concerning the Roberts. No foster care service plan was ever filed with the court by the Department of Social Services recommending that custody of this child be awarded to the Roberts. Consequently, the Amherst County Juvenile and Domestic Relations Court lacked jurisdiction to award custody of this child to the Roberts. Martin v. Pittsylvania County Department of Social Services, 3 Va. App. 15, 348 S.E.2d 13, 18 (1986), Lowe v. Grasty, 203 Va. 15, 122 S.E.2d 867 (1961).
The father was released on parole on sentences totaling five years and ten days in prison, all for contempt for violation the aforementioned orders of the Amherst County Juvenile and Domestic Relations Court. The father has successfully completed his parole and is free to travel. However, as shown above, that court was without the power or the jurisdiction to issue those orders. It is well established that a father cannot be found in contempt for failing to comply with orders which are jurisdictionally void. Kogon v. Ulerick, 405 S.E. 2d 441 (1991), Bryant v. Commonwealth, 198 Va. 148, 93 S.E.2d 130 (1956); New York RR Company v. Commonwealth, 196 Va 428, 83 S.E.2d 782 (1954), Buchanan v. Buchanan, 170 Va. 458, 197 S.E.2d 426 (1938); Hamstead v. Dostert, 313 S.E.2d 409 (W.Va. 1984).
All of the above points do not depend in any way on a transcript or a statement for facts. They are all apparent from the complete record. Even if it had been possible to make a transcript, the transcript would have contained nothing useful or enlightening for the court. It is most unfortunate that this case has gone on for the last ten years since 1986 and that the father never has been able to obtain judicial review by any appellate court of these jurisdictionally void proceedings, all due to the deliberate procrastination and delay first by the Amherst County Juvenile and Domestic Relations Court and then by the Amherst County Circuit Court.
Finally, I want to say that of the 15 or 16 appeals I have filed in this case, only once has this case ever been set for oral argument. That oral argument was scheduled to be held before a panel of the Virginia Supreme Court on September 6, 1991 at 10:30 AM. Charles and Shelby of course knew about this date and they therefore contrived to have me arrested on the afternoon of September 5, 1991, just as I was getting ready to drive to Richmond for the oral argument. As a result, I never got to present my argument to the court. Since then, the courts have refused to schedule an oral argument for any of my appeals. In my criminal case, I also requested the opportunity to argue my own appeal, because I knew that my court appointed attorney would be presenting a weak argument. This was also denied. I believe that if I had been allowed to present that argument, my criminal conviction would have been reversed. Instead, it was upheld by an en banc 6-3 vote.
It addition, at the criminal trial, the prosecutor lied repeatedly to the jury. For example, she stated that it was not true that I was scheduled to present oral argument to the Virginia Supreme Court on September 6, 1991, even though court records clearly show that such oral argument had been scheduled. The jury was also told that I had been guilty of kidnapping my daughter in New York State even though I have never been charged with a crime in that state and, even if I were, the jury was not supposed to be told about it. There is a long list of outright lies which the prosecution said and indeed had to say just to secure my conviction so that Charles and Shelby Roberts would get to keep the custody of my daughter.
Again and again, on each and every occasion and opportunity, the father has objected to the jurisdiction of the courts of Virginia on the grounds of the Uniform Child Custody Act, the International Child Abduction Remedies Act, 42 USC 11601, and the Hague Convention. On no occasion has the father or the mother ever agreed that the courts of Virginia have jurisdiction over the custody of this child.
Now, this court joins this criminal conspiracy to kidnap my daughter by refusing even to allow me to argue my appeal. Accordingly, I demand that this appeal be reinstated and that I be allowed to present this case.
Finally, I want to mention that all of the facts and details of this case, including photographs, have been published on the Internet and the World Wide Web, especially at the address of http://www.ishipress.com/index.htm
Accordingly, if this court continues to sweep this case under the rug and to deny me a hearing on my rightful claim to custody of my kidnapped child, the entire world will know about it. The world will know that the international kidnapping of a child from a foreign country will go unpunished in Virginia and that the kidnappers will be rewarded, shielded and protected from criminal prosecution here.
For all of the reasons set forth above, this petition for a rehearing and a rehearing en banc must be granted and upon rehearing the decision of the trial courts must be reversed and these proceedings must be dismissed and the child must be returned to the custody of her father or in the alternative this case should be remanded to the trial court for determination based upon a proper record.
Appellant requests oral argument of this appeal.
DATED: November 28, 1996
M. Ismail Sloan
2420 Atherton St., Suite 6
Berkeley CA 94704
Tel: (718) 638-5153
FAX: (718) 857-8613
VIRGINIA: IN THE COURT OF APPEALS OF VIRGINIA
RECORD NO. 1389-96-3
M. ISMAIL SLOAN,
v. Circuit Court No. 9216
CHARLES E. ROBERTS and SHELBY H. ROBERTS
PETITION FOR A REHEARING AND REHEARING EN BANC
M. ISMAIL SLOAN
2420 ATHERTON ST., SUITE 6
BERKELEY CA 94704
Tel: (718) 638-5153
FAX: (718) 857-8613
E-Mail Address: Sloan@ishipress.com
TABLE OF CASES
Alison D. v. Virginia M, 77 N.Y.2d 651, 586 N.Y.S.2d 586 (Ct.App. 1991) 7
Anderson v. Commonwealth, 13 Va. App. 506, 413 S.E.2d 75 (1992) 1, 6
Barrett v. Barrett, 1 Va. App. 378, 380, 339 S.E.2d 208, 210 (1986) 1
Bryant v. Commonwealth, 198 Va. 148, 93 S.E.2d 130 (1956) 12
Buchanan v. Buchanan, 170 Va. 458, 197 S.E.2d 426 (1938) 12 12
Goodpasture v. Goodpasture, 7 Va. App. 55. 57, 371 S.E.2d 845, 846 (1988) 1
Hamstead v. Dostert, 313 S.E.2d 409 (W.Va. 1984) 12
Jordan v. Price, 3 Va. App. 672, 353 S.E.2d 168 (1987) 1
Kogon v. Ulerick, 405 S.E. 2d 441 (1991) 12
Lowe v. Grasty, 203 Va. 15, 122 S.E.2d 867 (1961) 3, 12
Martin v. Pittsylvania County Department of Social Services, 3 Va. App. 15, 348 S.E.2d 13, 18 (1986) 3, 12
New York RR Company v. Commonwealth, 196 Va 428, 83 S.E.2d 782 (1954) 12
Rader v. Montgomery County Department of Social Services, 5 Va. App. 523, 526, 365 S.E.2d 234, 236 (1988) 4
Santosky v. Kramer, 455 U.S. 745, 769 (1982) 11
Smith v. Organization of Foster Families, 431 U.S. 816, 842 (1977) 5
Stanley v. Fairfax County Department of Social Services, 395 SE2d 199, 207, 10 Va. App. 596 (1990) 3
Stanley v. Illinois, 405 U.S. 645 (1972) 11
Turner v. Commonwealth, 2 Va. App. 96, 341 S.E.2d 400, (1986) 1, 6
Wright v. Arlington County Department of Social Services, 9 Va App. 441, 388 S.E.2d 477 (1990) 11
Hague Convention 13
International Child Abduction Remedies Act, 42 USC 11601 13
Uniform Child Custody Act 13
CERTIFICATE OF SERVICE
Samuel H. Sloan states that on November 28, 1996 he served the within opening brief of the appellant by mailing a true copy of the same to the following:
Charles and Shelby Roberts
420 Amelon Road
Madison Heights, VA 24572
J. Thompson Shrader
P. O. Box 428
709 South Main Street
Amherst, Virginia 24521
Lisa L. Schenkel
1602 Graves Mill Road
P. O. Box 11315
Lynchburg, Virginia 24506
Honzagool c/o Raja Abdul Rashid
House No. 252, Street No. 52
Samuel H. Sloan