PETITION

TO THE HONORABLE JUDGES OF SAID COURT:

Your petitioners, Charles and Shelby Roberts, husband and wife, respectfully represent as follows:

1. The infant child, who is the subject of this Petition, was born on October 15, 1981 in New York.

2. The natural father is Mohammed Ismail Sloan, AKA Samuel Sloan, whose last known address in P. 0 Box 4829, Fujairah, United Arab Emirates.

3. The natural mother is Honzagool (Sloan) whose last known address is Village Damik, P. O. DROSH, Chitral District, N. W. F. P. Pakistan.

4. Your petitioners are Charles and Shelby Roberts, who reside at 420 Amelon Road, Madison Heights, VA.

5. The natural mother was granted custody of Shamema in 1981 in New York, however, the natural father left the state with the child and moved to Lynchburg. The natural mother has had no contact with the child since she was several months old.

6. The natural father placed the child with the petitioners in 1982. The original purpose of that placement was that the father needed someone to care for the child on a temporary basis for a short period of time. The child was left with the Petitioners from age nine months until nearly five years of age.

7. The child grew up in the petitioners' home until the age of five. During this time the father visited infrequently and had little or no contact at all for long periods of time.

8. On April 2, 1986, this Court took temporary jurisdiction of the case under the Uniform Child Custody Jurisdiction Act and Federal Parental Kidnapping Act, placing temporary legal custody jointly with the father and with Mr. and Mrs. Roberts with Mr. and Mrs. Roberts retaining physical custody and ordered that the child not be removed from the jurisdiction without Court approval.

9. On August 25, 1986 this Court ordered that Mr. and Mrs. Roberts be allowed to enroll the child in Temple Christian School and that the father was to have physical custody on September 7, 1986 with visitation allowed to Mr. and Mrs. Roberts.

10. On September 5, 1986 this Court found that the father had failed to return the child from visitation; that the child was considered a missing child and that when found, the child should be seized and was henceforth in the custody of the Amherst County Department of Social Services.

11. On or about September 5, 1986, the father took the child to Argentina, and other countries and finally resided in Abu Dabi, United Arab Emirates and later moved to Fujariah, U. A. E.

12. During the period from 1986 – 1990 the child lived without adequate supervision for many periods of time and was abused physically and emotionally.

13. On September 12, 1990, the Court in Thailand held that Shamema and two (2) other children were abandoned in a guest room there and ordered that the child be returned to the United States; at which time the father absconded with the children taking them back to Abu Dabi.

14. On or about October 9, 1990, the child was brought to the United States by a housekeeper and is now in the custody of the Amherst County Department of Social Services.

15. The father has made telephone calls to various people stating that he is coming to get the child.

16. The petitioners know of no other person not a party to this proceeding who claims to have custody or visitation rights with respect to this infant; except that the grandmother, Dr. Helen Sloan, at one time expressed an interest in custody.

17. The custody and visitation of this infant are subjects of controversy and require determination.

18. The petitioners know of no other custody proceeding concerning the child pending in a court of this or State.

WHEREFORE, your petitioners pray that:

1. The proper process be issued directing the natural father and mother to appear and answer this petition in court.

2. A guardian ad litem be appointed to represent the infant child.

3. The court order an investigation into this issue by the Amherst County Department of Social Services including psychological studies of the infant child and of the farther if he can be found.

4. Legal and physical custody of the infant child be placed with Mr. and Mrs. Roberts.

5. No visitation rights be granted to the natural parents.

6. Such other and further relief be ordered as may seem meet and the nature of this case may require.

CITY OF LYNCHBURG

TO-WIT;

The foregoing instrument was acknowledged before me this 19th day of October, 1990 by CHARLES ROBERTS.

My commission expires October 31, 1994

CITY OF LYNCHBURG

TO-WIT;

The foregoing instrument was acknowledged before me this 19th day of October, 1990 by SHELBY ROBERTS.

My commission expires October 31, 1994