Answer to New York Family Court Petition


In the Matter of a Proceeding under Article 8 of the Family Court Act

Dayawathie Rankoth,

Docket No. O 4214/1997
Ismail Sloan



Ismail Sloan, being duly sworn, deposes and says:

1. I reside at 1581 Park Avenue, Apt. 4G, New York NY 10029, with my legal wife, Dayawathie Rankoth, the petitioner herein. Our three children, Michael, George and Anusha, reside with us at that address.

2. I have resided at this address with my wife and children since she obtained this apartment in September, 1996. Previously, I resided with her at 905 Tinton Avenue, Apartment 4D, Bronx, NY.

3. Throughout the period that we have resided together at these addresses, I and my entire family have been subjected to constant harassment and annoyance from Sister Theresa Courtney of Sanctuary for Families. Although I have never met or spoken to Sister Theresa Courtney and would not know her if I saw her on the street, it is apparent to me that she is a very crazy lady who is intent on breaking up my family and depriving me of my wife and children and my children of their father.

4. This all started in June, 1991 when I checked my then pregnant wife and two children into a hotel in Queens. When I returned at noon to collect my wife and children and take them back to our home in Virginia, I found that I was not being allowed to enter the hotel. I sent a message to call my wife to come down and meet me outside. I was told that she had been on her way out the door to meet me when she had been detained by the hotel staff. I waited outside until late that night, but she never emerged. I searched for her for weeks thereafter. I never saw her or our children again for nearly four years until February, 1995.

5. When I finally found my wife again, through the Internet, she explained that on that fateful day Sister Theresa Courtney had been at that hotel. Sister Theresa had persuaded her to leave the hotel through the rear door. She had then been taken to a "safe house" near the Allerton Avenue Station on the 2 and 5 trains in the North Bronx. She had been unable to contact me because my telephone had been disconnected. She had been kept hidden by Sister Theresa for the next four years. She did not know where I was. There had been no way for her to contact me. She had never been given a copy of any of the letters which I and her friends had written to her which contained telephone numbers where she could contact us.

6. Almost simultaneously with the above events in June, 1991, I received a telegram from Sebastian Ike of the Bureau of Child Welfare of New York City asking me to contact him. Mr. Sebastian Ike informed me that his agency was just about to commence proceedings to remove the children from their mother. Apparently, in such a situation there is a legal requirement to notify the father that this is happening. I went to see Mr. Sebastian Ike at his office at 4th Avenue and 12th Street in New York City. I gave him copies of our marriage certificate, her passport and other documents pertaining to her case. Then, in order to anticipate any proceedings by his agency, I started my own proceeding for the custody of these children in the New York Family Court.

7. A few days later, I was informed by Mr. Ike that my wife and the children had disappeared and that they were unable to locate them. Mr. Hans Steiner of the New York Society for the Prevention of Cruelty to Children was appointed guardian ad litem for the children. That agency was also unable to locate my wife and the children either after many months of searching. We now know that the reason that none of us could find my wife or the children is that they were being hidden in the North Bronx by Sister Theresa Courtney and Sanctuary for Families.

8. The petition filed in this case is filled with lies. Not one substantive allegation in the petition is true. For example, it is alleged on page 2: "Respondent had previously been convicted of the federal crime of child abduction in the case of another child born of a mother he had illegally transported from Pakistan into the United States. Respondent was sentenced in this case to five years in federal prison."

8. None of this is true. I have never been convicted of the federal crime of child abduction. I have never been sentenced to five years in federal prison. In have never been charged with any federal crime at all. I have never been tried or convicted of any federal offense. I have never transported a woman illegally from Pakistan.

9. What did happen however is that in 1980 I married a woman legally in Pakistan. I brought her legally to the United States on an immigration visa approved by Stephen Schlaikjer, the United States Vice-Consul in Islamabad, Pakistan. After arriving in America, my wife obtained a green card. Unfortunately, some other Pakistanis in New York City thereafter discovered me living with my wife and started harassing us. They constantly harassed and annoyed me and my wife for the next two and a half years. Cases were started in the Bronx Family Court and Bronx Supreme Court over the custody of our daughter, Shamema. Eventually, my wife, Honzagool, was essentially compelled by these Pakistanis to return to Pakistan. She left our daughter behind with me. She never returned. This was in 1982. Honzagool has never been seen or heard from since. It is said that she is married to a brother or cousin of the ringleader of the group that was harassing me in New York and that she now has three children by that man.

10. At no time have I ever been remotely charged or accused of any crime in connection with this entire matter.

11. In 1990, Charles and Shelby Roberts, Christian Fundamentalists connected with Jerry Falwell in Lynchburg, Virginia, successfully hired and paid a professional kidnapper to kidnap our daughter Shamema and have the child brought to them. Charles Roberts has been charged with the crime of kidnapping in the United Arab Emirates where this offense occurred. However, the US authorities have refused to prosecute him. After bringing our daughter to Virginia, Charles and Shelby Roberts filed a petition for the custody of Shamema. The Virginia court clearly had no jurisdiction, as custody had previously been awarded by Judge Anthony Mercorella of the Bronx Supreme Court in the case Sloan vs. Awadallah, Bronx Supreme Court, 17815/1981. Nevertheless, incredibly, the local Virginia county judge, Judge Lawrence Janow, issued a non-appealable order "awarding" custody temporarily to the Amherst County Department of Social Services, with the understanding that Charles and Shelby Roberts would be appointed as foster parents. Seven months later, Judge Janow awarded the Roberts custody of my kidnapped daughter, but with visitation to me. The Roberts never gave me any visitation. Only six weeks after having been awarded custody of my daughter, when I tried to visit my daughter, the Roberts had me arrested on the charge of the attempted abduction of my own daughter.

12. Charles and Shelby Roberts are in active contact with Sanctuary for Families and Sister Theresa Courtney. Almost all of the false information contained in the petition herein is supplied by the Roberts. On April 21, 1997, the date when the instant petition was signed, Sanctuary for Families put my wife, Dayawathie Rankoth, on the phone with Charles Roberts for about 20 minutes. She was compelled to listen to this constant stream of lies from Mr. Roberts. They did this so that she would sign the affidavit containing these false statements by Mr. Roberts.

13. Sanctuary for Families and their lawyers are in constant contact and communication with Charles and Shelby Roberts in Lynchburg Virginia. My wife has been told that the Roberts will be coming to testify against me in the trial before this court. I do not believe that the Roberts will attend court however, as they are subject to arrest for kidnapping my daughter. They certainly will not be bringing my daughter to New York, as I have been awarded her custody by Judge Lauren Backal of the Bronx Supreme Court, Sloan vs. Awadallah, 17815/1981.

14,. Similarly, paragraph 7 alleges: "Upon information and belief, more than twenty complaints have been filed against respondent with the United States Department of State for the illegal trafficking of women from developing countries." I am not aware of any such complaint having been filed. If such a complaint has ever been filed, it was filed by Charles and Shelby Roberts and by Sanctuary for Families, the petitioners here. The Roberts and Sanctuary for Families are making complaints against me solely for the purpose of obtaining custody of my children. There is no basis to any of their self-serving complaints.

15. Turning to the more recent events, the petition alleges: "On April 20, 1997, at 6:00 AM, Respondent came to petitioner's apartment, knocked in the door and entered the apartment without authority from the petitioner. Respondent told petitioner that he had come to take Michael and George to California. Petitioner ran to her bedroom and called 911. Respondent took petitioner's keys. The police arrived and returned petitioners keys to her and took respondent out of the building."

16. Almost none of this is true. The only part that is true is that the police arrived and took respondent out of the building. Regarding the rest, exactly the opposite is the case. I have been living in the subject apartment since September, 1996, when the apartment was first occupied, except that I was away for three month to attend a stockholders derivative suit in federal court in California. Since I returned in February, 1997, I have slept every night in the subject apartment, except when I went to Virginia for three days during the period April 12-15. I could easily call dozens of witnesses who could testify that I have been coming and going to the apartment on a daily basis.

17. I went to sleep in my bed in the boy's bedroom at 10:30 PM on the night of April 19. Only myself, my wife and the four children were present when I went to sleep. Michael was sleeping in his bed across from me. I awoke at about 5:00 AM because of a loud commotion in the living room. Michael was now sleeping in bed with me. I observed Jean, a known prostitute who is a friend of Dayawathie, sleeping with her daughter in Michael's bed. I went out to discover Jimmy, a man from Bangladesh, having an argument with someone. (I did not enter the room and do not know who the argument was with but he seemed to be arguing over the telephone). In the girl's bedroom, my son George was now sleeping in the floor. A woman named Brenda was sleeping there as well.

18. All of these people, Jimmy, Jean, Jean's daughter, and Brenda were well known to me because they had been frequenting my wife's apartment. These were only a few of the menagerie of homeless people who had been coming there. Not present on this occasion were Julie and another Brenda. The other Brenda had spent the pervious night in our apartment. She had only recently gotten out of jail. She had given birth by Cesarean Section to a crack addicted baby only two weeks before. The CWA had immediately taken the baby away from Brenda. Brenda had then come to my wife's apartment, without invitation. Brenda (also known as "Black Brenda" or "One-Legged Brenda") had been having sex with men as a prostitute without waiting for her Cesarean wound to heal. 911 had been called four times the previous night because of this and also because of the chest pains which Dayawathie has been having. Both had been taken by ambulance to Metropolitan Hospital, leaving me to care for the four children. Brenda had been admitted to the hospital. Dayawathie had returned home after some hours.

19. Shortly after I awoke on the morning of April 20, Jimmy started playing with my computer. This is a spare 386 computer I had brought from my office for my children, Michael, George and Anusha to use to learn computing. Jimmy had used my computer and had deleted some programs I had set up for my kids to use. I told Jimmy to get off of my computer. An argument ensued and Jimmy started making physical threats against me. Jimmy, being a homeless street person, usually goes to sleep at about 6:00 AM and then sleeps all day. I waited for Jimmy to go to sleep and then called 911. I called 911 and reported that homeless street people and crack addicts were sleeping in my apartment and I needed to get them out. My wife, Dayawathie Rankoth, heard me make the call.

20. When 911 called back to conform the call, Dayawathie answered and told them to come. However, when the police arrived, Dayawathie told them that the homeless people were her friends and that she wanted them to stay there, but that she wanted me out. She told the police that I had taken her key. I told them (correctly) that she had never given me the key. The reason for this is that about one week before I had changed the lock on the door. I had gone to the locksmith at 120th Street and Third Avenue and purchased a new cylinder and installed it myself. Dayawathie asked me to do this because Jimmy had the key to the apartment and refused to give it back. He was in the habit of entering the apartment at about 4:00 or 5:00 AM and sleeping all day there. Dayawathie said that she wanted him out. However, after changing the locks on the door, Dayawathie had continued to let Jimmy in whenever he came there.

21. After the police took the key away from me on the morning on April 20, it was placed on the TV. The key promptly disappeared. It was presumably taken by Jimmy. As a result, Dayawathie has been forced to change the locks again to keep Jimmy out. I believe that the police acted improperly in taking the key away from me without an order of the housing court.

22. Dayawathie calls me at my office an average of 10 to 20 times per day. She called about 15 times yesterday. She creates such a nuisance during working hours that my boss keeps telling me to control her calls. Because of her constantly calling me, I know exactly what has happened in the apartment after I left.

23. After I left the apartment, escorted by the police, Dayawathie Rankoth called a friend from Afghanistan. That man arrived in the afternoon. Dayawathie shouted at Jimmy and told him to get out of the apartment. Jimmy refused to leave, so the man from Afghanistan hit Jimmy over the head and escorted him out of the apartment.

24. However, according to my daughter Anusha, Dayawathie called Jimmy on his beeper the following day and asked him to come back. Jimmy arrived but Dayawathie then said that she wanted to fight with him some more. Jimmy refused to fight but left instead. This event happened on the same day and a few hours after this court signed the order of protection.

25. I wrote my letter to the court on Tuesday April 22 and it arrived on Wednesday April 23. This date is significant because that was the day that Dayawathie was to receive her welfare check. The day is known to the others because One-Legged Brenda has the same last number on her welfare case number and receives her check on the same day. Whenever Dayawathie receives her welfare check, Julie and Jean, among others, come to Dayawathie's apartment to "borrow" her money. This has been going on for years and so far they have never paid her any of the money back.

26. At 6:00 AM on the morning of Wednesday, April 22, Jean knocked loudly on the door to be let in to await for Dayawathie's welfare check. Dayawathie and the other Brenda, who had spent the night in the apartment, went out to collect the check, leaving Jean in the apartment. Jean, who weighs nearly 200 pounds, ate all the food. The phone rang several times and Jean answered. Jean should not have done this because she was not supposed to be living in the apartment. The housing manager called and found out that Jean and several other homeless people had been living there. Apparently, Kathleen from Little Sisters also called. Alerted by my letter which arrived at that time, Sister Theresa Courtney, plus Kathleen from Little Sisters and the lawyer for Sanctuary for Families all went to the subject apartment. They arrived just in time to find the entire crew, including Jean, Julie and Brenda, the same persons about whom I had written in my letter, all assembled to divide up Dayawathie's welfare check. Jean even told the lawyer, the nun and the social worker to take their conversation elsewhere because she was going back to sleep. (This was at about 3:00 PM).

27. I am sure that the lawyer, the nun and the social worker thought about calling 911, just as I had done four days earlier. I imaging that they are less enthusiastic about this case then they were when they filed this case two days earlier.

28. All of the above can be verified. The above events were witnessed by dozens of people. 911 keeps a record of all calls received. It can be verified that I called 911, not Dayawathie Rankoth. The police can be interviewed as to the condition of the apartment when they arrived.

29. Also there are hospital records and doctors reports showing that when my children become sick, I am the person who takes my children to the hospital, not Dayawathie. I had just finished taking my son George to the emergency room of Metropolitan Hospital a few days before. Furthermore, my office staff can verify that my wife calls me repeatedly throughout the day and that I have on several occasions brought my children, Michael, George and Anusha to the office. Lately, she has been sending messengers to pick up money from me at my office

30. While I have been living with my wife, I have been giving her money every day. Actually, she goes into my pockets while I am sleeping and takes my money, leaving me only one token to get to work. Because I have not been in the apartment for the last two weeks, she keeps calling to ask for money. She sends Brenda plus one of my children to my office in Brooklyn to pick up money from me. On Monday, April 28, because she was under surveillance by Sanctuary fir Families, she could not come here to collect money. Instead, she went to see Poppy the Loan Shark, at his residence on 168th Street and Tinton Avenue in the Bronx. According to Dayawathie, she was followed on the train by a man from Sanctuary for Families. He waited outside while she went inside to borrow $100 from Poppy the Loan Shark. She must now repay this with $150 from her next welfare check which she will receive on May 9. She had been making extensive use of loan sharks during the four years when she had been hidden by sister Theresa Courtney and Sanctuary for Families. She especially used a loan shark named "Panama" who would take her welfare card and hold it as security until her welfare check came. While I have been with her, she has not resorted to the use of a loan shark but will continue to be needing one while I am away.

31. Regarding the other allegations in the petition, none of it is true. The petition alleges that in 1987 I came to her house with another man and offered to hire her to work in Virginia to take care of my mother. Too the contrary, on July 5, 1987, she came to my hotel, which was the Queens Hotel in Kandy, Sri Lanka with a man named Norris and asked for a job. I never really offered her a job. She simply never left. My mother and daughter, Shamema, were there with me in the hotel. Her first night with us, she spelt in the same bed with my mother. A few days later, I rented a five bedroom house in Anawatta, Kandy, Sri Lanka. Before long, Dayawathie moved into my bedroom. Soon, she was pregnant. We stayed in Sri Lanka for three months until October, 1987, living about 5 miles from her mother's house. We then flew to Thailand where we stayed about six weeks. We then flew to Abu Dhabi. However, she was rejected for entry into the UAE after making a commotion in the airport. She was sent back to Sri Lanka. She went back to her mother's house. I obtained a visa for her and sent her airline tickets. She came herself to the UAE, arriving in late November, 1987. Our son, Michael, was born on June 18, 1988. All this can be proven by stamps in her passport.

32. Thus, the claim made in the petition that I raped and assaulted her in Dubai by tying her tying her hands with a stocking and forcing her to submit to sexual intercourse is palpably false, as it can be proven that she was already two months pregnant when she first arrived in Dubai.

33. I obtained a US visa for Dayawathie and took her to Oakland, California for the birth of our child, so that the child would be a US citizen. I arranged for her to stay with Sister Bernadine Dominik in the Casa Vicienta, a home for unwed mother's in Oakland. After Michael was born, Sister Bernadine tried hard to convince Dayawathie to remain with her under the umbrella of her organization. However, Dayawathie insisted on going back to the United Arab Emirates with me.

34. In February, 1989, Dayawathie was arrested essentially for disturbing the peace and held three days in jail in Fujairah, United Arab Emirates. Upon release from jail, she was asked to leave the country and to go back to wherever she came from. She returned to Sri Lanka that night, leaving our six month old son, Michael, with me and my mother and daughter.

35. I traveled twice to Sri Lanka in an effort to bring her back and rejoin our child. Because the UAE authorities were no longer willing to allow Dayawathie to enter the country as a worker, I had no choice but to marry her if I wanted to keep her with me. I took her to the Colombo Kacherie (Marriage License Bureau) and married her on August 9, 1989. She became pregnant with our second child George on virtually our wedding night. The reason I know this is that I left the Sri Lanka the next day. I could not stay longer because of the civil war going on in Sri Lanka with bombs going off and people fighting and killing.

36. With our marriage certificate, I obtained a "Wife Visa" in the United Arab Emirates. In November, 1989, I flew to Sri Lanka and went to her home in Bowalawatta, Kandy, Sri Lanka. The war was actively going on. Twelve people had been killed, mostly women and children, just 100 yards from her house, the day before. It took Dayawathie only five minutes to be packed and ready to go.

37. Upon arriving back in the United Arab Emirates, Dayawathie almost immediately started fighting and arguing with my family members. It seemed likely that she was going to be put in jail again. Rather then send her back to Sri Lanka and leave our unborn child to its fate, I obtained with great difficulty a second US visa. I brought her to America in February, 1989. On the same day as her arrival in America, I had to take her to the Emergency Room at Maimonides Hospital in Brooklyn. She was admitted as a patient into the hospital and remained there for a full month. She gave birth to George on April 28, 1989.

38. After giving birth to our second child George, Dayawathie got involved with The Reverend David Haberer and his wife Sharon Haberer in Far Rockaway, Queens. They had been referred to this matter by the Far Rockaway branch of Catholic Charities. David and Sharon Haberer also had dreams of adopting our children. I started a case for the custody of our children in the Queens Family Court. The case was adjourned several times. In January, 1991, Dayawathie ran away from the Haberers. She arranged for me to pick her up at a nearby Laundromat during the period of a half hour while Sharon Haberer went to pick up her children. I took Dayawathie, Michael and George to Virginia, arriving on January 14, 1991. She became pregnant with our third child Anusha shortly thereafter.

39. The petition implies that she went directly from Maimonides Hospital to a Battered Women's Shelter. This is not true. There was an incident at Maimonides Hospital in Brooklyn in May, 1991. Dr. Joseph, a lady doctor from India, called the CWA after she observed Dayawathie hitting one if the children. However, I several weeks later picked them up in my car and drove them to the Jamaica Arms Hotel in Queens. It was there that Dayawathie, Michael and George were intercepted by Sister Theresa Courtney and taken to a shelter.

40. In February, 1995, four years later, I located my wife in children living in a housing project in the Bronx at 905 Tinton Avenue, Apt. 4D under appalling conditions. It was in that building that she had met Julie, Jean and One-Legged Brenda, who were tenants in that building. I moved into the apartment the same night that I found them. Conditions were terrible. I spend the next two months cleaning up the apartment, which was incredibly dirty. In early April, 1995, Dayawathie asked me to take my two sons, Michael and George, to California, as they were too difficult to handle. I gave Dayawathie $400 and she bought them a new set of clothing and other presents for the trip. We made flight reservations. All this was done secretly so that Sanctuary for Families and Sister Theresa Courtney would not find out about it.

41. I was in California for nearly one month when I tried to enroll them in school. I took them to the Haight School in Alameda, California, which my daughter Jessica was also attending. The school in California called the school in Bronx which Michael and George had been attending. The Bronx school notified Sister Theresa Courtney, who did not know up until that time that the children were in California. The bubble burst. Sanctuary for Families filed a fraudulent habeas corpus petition in the New York Family Court which contained numerous false allegations. It alleged that Dayawathie Rankoth resided at 410 West 40th Street, New York NY, whereas in reality she resided at 905 Tinton Avenue, Bronx, New York. The purpose of this false allegation was to get this case presented to a judge known to them in the New York Family Court who was sympathetic to their case. Had the case been filed in the proper jurisdiction, that judge could not have been assigned.

42. The petition there contained virtually identical allegations to those presented here. On the basis of that petition, Sanctuary for Families was able to get me arrested in California and the two children extradited to New York. However, I was never charged. I never saw the inside of a courtroom. I was merely placed under a "hold" while the charges made by Sanctuary for Families were investigated. When nothing was found, I was released.

43. Upon the return of Michael and George, Sanctuary for Families found that my wife, Dayawathie, had become pregnant with our fourth child. They took her down and had the unborn baby aborted when Dayawathie was four months pregnant. By the time I got out of jail, OUR UNBORN BABY HAD BEEN MURDERED BY SANCTUARY FOR FAMILIES AND SISTER THERESA COURTNEY. They will burn in Hell for this. Rosemonde Pierre-Louis, the lawyer who arranged the abortion, even had the clinic save a tissue sample of our unborn child so that a case could be brought against me later on.

44. Almost immediately after this abortion, Dayawathie became pregnant from a man named Kamal Abdullah Mohammad from Bangladesh. The child, Geeta, was born on June 9, 1996. The father refuses to acknowledge the child.

45. In April, 1996, Sister Theresa Courtney and Sanctuary for Families found out that I was again living in the apartment at 905 Tinton Avenue, Apt. 4D, Bronx, New York. They forced her to vacate her apartment and go to live in their shelter near the Fort Hamilton Parkway Station of the F train in Brooklyn. As soon as she was in that supposedly "safe house" Dayawathie called to tell me the address, which was 1280 Prospect Avenue near Greenwood Avenue. I went to California, but came back on July 1, 1996 with my daughter, Jessica, the half-sister of Michael, George and Anusha. We waited next to the Fort Hamilton Parkway Subway Station of the F Train until Dayawathie and Anusha came out. Michael and George had gone away to Summer Camp Homeward Bound. I took Dayawathie and Anusha to the Burger King at the corner of Gold and Futon Streets near Beekman Downtown Hospital in Manhattan. We had a burger. I then took Jessica to Philadelphia for the World Open Chess Championship.

46. On August 2, 1996, I came again from California with Jessica. We waited outside the "safe house" but were immediately spotted by the watchman for Sanctuary for Families. The police came. We left, realizing that it was pointless trying to wait for Dayawathie and the children. I took Jessica to Virginia.

47. In late August, 1996, I came again. I realized that with my having been spotted, Dayawathie and the children would be moved to another safe house. It was on this occasion that I showed around her picture and that of our daughter. I wanted to be spotted so that Dayawathie would be informed that I was back in New York. Sure enough, Dayawathie was informed and she called me at my office that very night. She was still in a safe house. However, a week or so later she was moved to her new apartment at 1581 Park Avenue, Apt. 4G. She called me and I moved in the same day.

48. On one occasion about one month ago, Kathleen dropped by unexpectedly at about 9:00 AM. I was just getting out of the bathtub and getting ready to go to work. Upon hearing the voice of Kathleen, I barricaded the door. I waited in the bathroom for a half hour until she left. On other occasions I have taken my children, Michael, George and Anusha to the Manhattan Chess Club, the Marshall Chess Club, Central Park and other public places. I took them to the New York Chess Championship held at the New Yorker Hotel during the Week of March 29 - April 6, 1997. I have hundreds of witnesses who saw me with my children at these locations. Yet, my children are told by their mother that if they see Theresa they should hide and if they speak to Theresa not to tell her that they have been seeing their father.

48. Sanctuary for Families and Sister Theresa Courtney need to recognize that it is pointless to keep my wife in a safe house when she calls me immediately to tell me where it is. Not only that but I am exposing the addressees of all these safe houses on the Internet. I have several dozen pages devoted to this case posted on the World Wide Web, starting with the address . Included are numerous photos of me with my children. Sanctuary for Families is aware of this and has downloaded these pages and photos. It is also pointless to keep changing my wife's telephone number, when she immediately calls me to tell me what her new number is, as she did last Friday, April 25, when they changed her number again.

49. I am a good father and a good husband. I have never hit my wife or my children. The allegations made against me originate entirely from Charles and Shelby Roberts, who kidnapped my daughter, Shamema. At the same time, my children have suffered horribly because of the actions by Sanctuary for Families, which receives federal, state and local funding. They even promised to take care of their cat, Pasey, during the period from April to September, 1996 while Dayawathie and the children were in the latest safe house, but the cat was obviously put to death and was never returned.

50. I urgently request an immediate trial or hearing on these matters. The charges made in the petition are simply baseless rumors and innuendoes which have been made repeatedly without proof. In an incident involving David and Sharon Haberer, a case was brought in Queens Family Court in November, 1990 making virtually identical allegations. Judge Kron of that court was asked to postpone the case so that they could gather evidence to bring a stronger case against me and to prove their case. Judge Kron adjourned the case several times. They never produced any evidence at all. That was six years ago. They still do not have any evidence. Again, when they brought a habeas corpus petition in the New York Family Court in 1995, they dismissed their own case after they had extradited my children from California. I never got a hearing in any court. In another child custody case involving these children in New York Family Court in 1991, they refused to produce the mother or the children in court or even to acknowledge their existence. The got that case dismissed after more than one year of adjournments without any hearing being conducted either.

WHEREFORE, for all of the reasons set forth above, the temporary order of protection and order of temporary custody to the mother should be vacated and full custody of the subject children should be awarded to the father.

Ismail Sloan

Sworn before me this 5th
day of May, 1997



Samuel H. Sloan, being duly sworn states that on May 5, 1997 he served the within answer by mailing a true copy of the same to:

Dorchen Leidholdt
Counsel for Sanctuary for Families
105 Chambers Street
New York NY 10007

Samuel H. Sloan

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