CITY OF NEW YORK - COUNTY OF QUEENS
__________________________________________________X
In the Matters of:
:
SAMUEL SLOAN,
:
Petitioner
: Docket
# V-11657-05
-against-
:
DAYAWATHIE RANKOTH,
:
Respondent
___________________________________________________X
AFFIDAVIT IN OPPOSITION AND MOTION TO VACATE
ORDER TO SHOW CAUSE AND TO DISQUALIFY COUNSEL
FROM APPEARING IN THIS CASE
______________________________________________________X
PLEASE TAKE NOTICE that upon the annexed affidavit of Samuel H. Sloan
sworn to the 25th day of April, 2006, the Undersigned hereby moves
this court for a order vacating the order to show cause signed April
21, 2006 and petitioner renews his motion to disqualify Dorchen
Leidholdt and Sanctuary for Families and anybody under their
supervision including Jill M. Zuccardy from appearing as counsel in
this case.
___________________________
Samuel H.
Sloan
1664 Davidson
Avenue, Apt. 1B
Bronx NY 10453
[EMAIL PROTECTED]
917-507-7226
FAMILY COURT OF THE STATE OF NEW YORK
CITY OF NEW YORK - COUNTY OF QUEENS
__________________________________________________X
In the Matters of:
:
SAMUEL SLOAN,
:
Petitioner
: Docket
# V-11657-05
-against-
:
DAYAWATHIE RANKOTH,
:
Respondent
___________________________________________________X
AFFIDAVIT IN OPPOSITION AND MOTION TO VACATE
ORDER TO SHOW CAUSE
___________________________________________________X
Samuel H. Sloan, being duly sworn, deposes and says:
1. I make this affidavit in support of a motion for a order vacating
the order to show cause signed April 21, 2006 and I renew my motion to
disqualify Dorchen Leidholdt and Sanctuary for Families and anybody
under their supervision including Jill M. Zuccardy from appearing as
counsel in this case.
2. I have made this motion twice previously but apparently the court
does not appreciate the full extent of the situation. Now, Attorney
Jill M. Zuccardy has pulled an amazing and audacious dirty trick by
presenting a motion for an order to show cause to another judge, not
the judge who has been handling this case since January. That judge,
Lenora Gerard, not being familiar with the history of the case, signed
the order rather than refer it to the judge on this case.
3. The Order to Show Cause seeks an order directing the court
appointed forensic examiner, Dr. Mark Rand, to review and consider
certain documents including websites and other items commonly found on
the Internet.
4. When I was interviewed by Dr. Rand pursuant to his court ordered
examination of the parties, he told me that he was not going to be
considering or even looking at any websites or Internet materials. I
accepted this but apparently Ms. Zuccadry has not. Now, she has
submitted a bunch of web pages all of which are obviously inadmissible
as evidence. She wants to force Dr. Rand to review and consider these
Internet materials.
5. Dr. Rand is a highly qualified and renowned forensic psychologist.
He knows how to do his job. The job of any doctor is to examine the
patients, not to read and consider stuff on the Internet. Dr. Rand's
job is to interview and examine the subjects of the inquiry and to
report his findings to the court. His job does not include reading
Internet materials. Anybody can do that. It is obvious that Ms.
Zuccardy realizes that the interviews are not going well for her
client. She complains that Dr. Rand has refused to review certain
Internet materials. She asserts in paragraph 6, "It is essential that
these materials be brought to his attention."
6. It is obvious that Ms. Zuccardy has instructed her client not to
cooperate further with Dr. Rand and therefore Dr. Rand will not be
able to complete his report by the required court date of April 26.
Because of this interference with the work of a qualified
professional, I ask this court to disqualify Ms. Zuccardy from
appearing further in this case. Already this case has been delayed
nine months by the obstructionist tactics of Ms. Zuccadry and her
predecessor Alexander Karam. They should have been disqualified long
ago. This case was Instituted in July 2005. I have never been able to
get a hearing on this matter. Now, a hearing is scheduled for April
26, 2006, and Ms. Zuccadry is trying to torpedo this hearing with this
order to show cause.
7. This court seems to think that Dayawathie Rankoth has legal custody
of the three subject children. This is not true. No judge of any court
has ever ordered that Dayawathie have legal custody, nor would it
since Dayawathie Rankoth has been under continuous investigation by
ACS and its predecessor agencies for the past 15 years since 1991.
8. I tried to introduce ACS reports as evidence at the hearing of this
matter, but the court ruled that they were inadmissible. Now, Ms.
Zuccadry wants to introduce Internet materials which are even more
obviously inadmissible.
9. It is highly unfair and prejudicial that Ms. Zuccadry keeps
referring to herself as the "Director of the Child Protection Project
at Sanctuary for Families Center for Battered Womens Legal Services".
This title makes it appear that she is some sort of government servant
or that she is working closely with government agencies. It also
implies that my children are in need of protection from me and that
their mother is some sort of battered women.
10. In fact, however, the reality is completely different. Sanctuary
for Families is a completely private organization run by a notorious
lesbian Dorchen Leidholdt and known for kidnapping children from their
fathers. They got my children by kidnapping them.
11. Sanctuary for Families first became involved in January 1991,
which was 15 years ago, when Dayawathie was pregnant with Anusha. We
were living in my mother's house in Lynchburg, Virginia. I brought
Dayawathie and the two children to New York for a one-day visit. I put
them in a hotel for one night in Jamaica Queens. When I came back the
following morning to pick them up, I was told that they were on their
way down the stairs and out the door. I waited and waited. They never
came out. I spent the next four years searching for them. When I
finally did find them in 1995, I learned that when they were on their
way out the door, they encountered Sister Theresa Courtney from
Sanctuary for Families, who directed them out the back door rather
than out the front door. After that, they could never find me. They
were searching for me just as I was searching for them.
12. After I finally did find them in 1995, Dayawathie asked me to take
the two boys to California where I had been living and where Michael
and had been born, because the two boys were wild and out of control.
She also warned me not to tell Theresa, who would be extremely angry
if she found out. I took the two boys to California. A month later
Theresa found out. She got her lawyer to bring an entirely bogus
proceeding in Manhattan Family Court. The proceeding was bogus
because, among other things, neither Dayawathie nor the children were
living in Manhattan. They were living in Bronx. Attached is a copy of
the petition. Take a look at the address. It has the hand-written
address 410 West 40th Street, New York NY. The court will recall that
at the last hearing I asked Dayawathie whether she had ever lived at
that address. She testified that she never lived there. Thus, I have
proven that the address was fake. Her lawyer had used this fake
address because she was friendly with a judge in Manhattan but she did
not know any of the judges in the Bronx, so she wanted this case
brought in Manhattan.
13. Based upon this bogus proceeding using this fake address, Dorchen
Leidholdt had me arrested in San Francisco California and had the two
boys picked up and brought to New York. I spent 42 days in jail mostly
in Alameda County Jail in Santa Rita. However, I was never charged
with a crime. When I got out I tried to find my boys. They had
disappeared again as Dorchen had moved them. It took me another year
to find them and then I found them only because Dayawathie, their
mother, contacted me.
14. Meanwhile, when I had been with Dayawathie she had gotten pregnant
with our fourth child. When Sister Theresa Courtney, a Catholic nun,
found out that Dayawathie was pregnant with my child again, she forced
her to have an abortion. The abortion took place on July 7, 1995.
15. In 1997, I was living with Dayawathie in her apartment at 113th
Street and Park Avenue in Manhattan. Again, this relationship was kept
secret from Dorchen and Theresa. Eventually, Dorchen found out.
Dayawathie called me at my place of employment on Sixth Avenue and
Pacific Street in Brooklyn and warned me not to come home as Dorchen
was trying to have me arrested. I went to stay with an Afghan friend
in Far Rockaway. A few days later, Dayawathie called to say that
Anusha was sick and had to be taken to the hospital but she could not
take her because she could not take her other two children to the
hospital. Dayawathie called me to ask me to come from Far Rockaway to
Spanish Harlem to either take Anusha to the hospital or to take care
of the children while she took Anusha to the hospital.
16. I made the two hour trip from Far Rockaway Queens to Spanish
Harlem. When I got there it all turned out to be a trap. Anusha was
not sick. Dorchen Leidholdt had set the trap to have me arrested. The
police were waiting for me in the apartment.
17. I was arrested and taken to jail. After six days I was due to be
released as no charges had been brought, but I was rearrested after
never getting out. I was held for another six days, so I was there for
a total 12 days. When the hearing date came, Dorchen Liedholdt wrote a
letter to the court saying that she could not prove her cases and
therefore she would not be coming to the court. I was released.
Needless to say, Dorchen had moved Dayawathie and the three children
again and it took me another year before I could find them.
18. In all of these cases, no custody order, neither temporary nor
final, was ever entered. Thus, I have the same legal right to these
children as does Dayawathie. Actually, I have greater right because
the children were taken from me by illegal means. As this court is
well aware, on January 6, 2006, Sanctuary for Families had me arrested
again. I was held for five days in the lunatic asylum. Again,
Sanctuary For Families accomplished this by making a bogus claim. They
claimed that I have been convicted of a federal crime by a federal
judge. No such thing has happened. I have never even been charged with
a federal crime much less convicted of one. I was released after five
days with a letter from a psychiatrist stating that there is nothing
psychiatrically wrong with me and there are no warrants for my arrests
or criminal charges pending against me. Again, I have proven that
Sanctuary for Families has lied.
19. I think that enough is enough. Sanctuary for Families is an
organization of criminals and liars headed by Dorchen Leidholdt, the
number one criminal and liar. They should be removed and disqualified
from appearing in this case. In addition, this court should refer this
entire matter to the disciplinary committee of the state bar.
WHEREFORE, for all of the reasons set forth above, the order to show
cause dated April 21, 2006 should be vacated and Dorchen Leidholdt,
Jill M. Zuccardy and Sanctuary for Families should be disqualified
from appearing as counsel in this case.
___________________________
Samuel H.
Sloan
1664 Davidson
Avenue, Apt. 1B
Bronx NY 10453
[EMAIL PROTECTED]
917-507-7226
Sworn to before me this 25th Day
of April, 2006
_______________________________
NOTARY PUBLIC
AFFIDAVIT OF SERVICE
Docket #
V-11657-05
STATE OF NEW YORK, COUNTY OF QUEENS SS:
Kayo Kimura, being sworn says: I am a party to this action and I am
over 18 years of age.
On April 25, 2006, I served a true copy of the attached affidavit, in
the following manner:
By mailing a true copy of the same to:
Jill M. Zuccardy
Attorney for Sanctuary for Families
67 Wall Street, Suite 2211
New York NY 10006
www.sanctuaryforfamilies.com
(212) 349-6006 ext. 320
Vladimir Cadet
89-31 161st Street, Suite 505
Jamaica NY 11432
718-297-0004
________________________
Sworn to Before me this 25th
Day of April 2006
_________________________
NOTARY PUBLIC
ForumWebSiteAt http://groups.yahoo.com/group/Libertarian
YAHOO! GROUPS LINKS
- Visit your group "Libertarian" on the web.
- To unsubscribe from this group, send an email to:
[EMAIL PROTECTED]
- Your use of Yahoo! Groups is subject to the Yahoo! Terms of Service.
