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