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

Dayawathie Rankoth,

Docket No. O 4214/1997
Petitioner
-against-
Ismail Sloan

Respondent.
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MOTION TO VACATE EX-PARTE TEMPORARY ORDER OF PROTECTION

Ismail Sloan, being duly sworn, deposes and says:

1. I hereby move to vacate the temporary order of protection and temporary order of custody of my two children which was granted by this court on April 21, 1997.

2. The petition presented in support of the motion for an ex-party order of protection is without factual basis. If they have any evidence at all in support of these allegations, they should present this evidence now. I can assure you that they have none.

3. Because of the allegations made by Sanctuary for Families, Inc. the police have been coming every day to my place of work, leaving me in dire danger of losing my job. They should be told to stop now.

4. My wife, Dayawathie Rankoth, calls me between 10 and 20 times every day. She asks me to come and meet her at various locations. She asks me to bring her money. She sends messengers to my office to pick up money from me. She does not want me excluded from our family home. Rather it is Sanctuary for Families and Sister Theresa Courtney who wants me excluded.

5. Previously, Sister Theresa Courtney had my wife and children placed in a "safe house" near the Allerton Avenue Station in the 2 and 5 lines in the North Bronx. More recently, she had my family in a safe house located at 1280 Prospect Avenue, Brooklyn, near the Fort Hamilton Parkway Station of the F train in Brooklyn. Every time my wife and children is put into one of these supposedly safe houses, my wife calls me to tell me where the safe house is. Every time they change my wife's telephone number, she calls me to tell me what the new number is.

6. My wife and children want me. Yesterday, my wife sent a messenger to pick up $11.50 from me so that our daughter can go on a field trip at her school with their teacher Mrs. Garcia tomorrow, Wednesday, May 7.

7. I have been living with my wife in her apartment since February, 1995, except during periods when she had been in a "safe house" or I have been in California. There are dozens of witnesses who can testify to this.

8. The ex-party order of protection deprived me of my wife, my children and my place to live all without a hearing and due process of law. It must be vacated immediately.

_________________________
Ismail Sloan

Sworn to before me this 6th
day of May, 1997

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NOTARY PUBLIC