[Editor’s note: The affidavits on this page documents the legal advice and personal assistance that Tim Stoen gave to individual members of Peoples Temple. They have been arranged in alphabetical order by last name of the affiant. In instances where several versions of a single affidavit appear in these pages, the most complete – and sometimes, the only legible – copy is fully transcribed, with legible earlier drafts appended. The PDF for this page presents the same affidavits in sequential by RYMUR number.
[This page ends with notes of conversations of Temple staff as to the nature of the campaign for affidavits they were working towards.
[Temple lawyers reviewed and approved the affidavits, Eugene Chaikin signing off with his initials “E.C.” or “Gene”; June Crym with “J.C.”; and Harriet Tropp with “H.T.”
[Minor typographical errors have been corrected throughout these affidavits. In addition, because many of the texts in this document were early drafts, the handwritten insertions and corrections by Temple attorneys have been incorporated as part of the text. Only the most significant changes in language have been noted.]
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FF-2-134
Affidavit of Stephen Addison
I profession I am a psychiatric technician. I have been a member of Peoples Temple of the Disciples of Christ (“the church,” ”Peoples Temple”) since 1959 and I have known Timothy O. Stoen (Tim Stoen) from around 1969 to 1977. After joining the church, Tim Stoen very quickly became involved in church affairs and was introduced to myself and others as the attorney for Peoples Temple.
In late 1971 Tim Stoen gave me legal advice on obtaining a divorce and appeared on my behalf in the Superior Court of Mendocino County in the matter, in front of Judge Brauddus.
Over the years, Tim Stoen frequently gave legal opinions and advice on church affairs, speaking as the attorney for the church in public church services in Peoples Temple churches, as well as giving such advice and opinions to individual members.
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FF-2-146B
Rough 9/2 HT
1. Stephen M. Addison – psychiatric technician
PT since 1959 – TOS – since he first came to the church in Redwood Valley, in 1969 or 1970. He quickly became involved in church affairs and was introduced to myself & others as attorney for Peoples Temple.
2. In late 1971 I talked to TOS about getting a divorce. He agreed to take the case, and he appeared on my behalf in the Superior Court of Mendocino County in front of Judge [illegible name] in the matter.
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FF-2-112
Affidavit of Geraldine Bailey
I am a retired Deputy Marshal (Los Angeles County). I joined Peoples Temple of the Disciples of Christ (“the Temple”) in 1971 and in 1973, I was referred to Mr. Timothy O. Stoen by a fellow member. He introduced himself as the attorney for the Temple.
In 1975, I was involved in a civil suit in which it became necessary for me to answer interrogatories. Tim advised me in the answering of the interrogatories.
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FF-2-118
Affidavit of Cathy Barrett
I am a waitress. My family joined Peoples Temple of the Disciples of Christ in 1955. I met Timothy O. Stoen in 1970 when it was announced by Tim that we could consult him for legal advice.
Tim asked me to speak to a Mendocino County sheriff who was a friend of mine in order to get the sheriff to drop the charges against a client of Mr. Stoen’s. This occurred in 1976.
[Handwritten notes: “Do not use – consult – E.C. [Eugene Chaikin]”]
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FF-2-163
HT Rough 9/2
Jack Baron [Barron] – profession: chemical engineer
PT since April 1971 – TOS since that time.
He introduced himself to me.
In 1973 I went to see Tim Stoen in his assistant DA office in Ukiah and got legal advice on an employment issue. He also referred me to another attorney and wrote a referral to that person on my behalf.
I arrived in Guyana in July of 1974 and have been here since. I last saw TOS in spring 1977, in Guyana, in Jonestown. During that spring I participated in discussions when he spoke as our attorney, giving legal advice with respect to the acquisition of real property in Guyana, and matters pertaining to the US legal affairs of Jonestown residents. In particular, I discussed my California divorce proceeding with him.
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FF-2-15A
Affidavit of Jack Lovell Beam: (1 of 2)
[handwritten notation at top of page: “develop human service motif”]
I have been a member of the Peoples Temple, the original and predecessor organization, (“the temple”, “the church”) since 1949, one of the founding members. The Temple has always been an activist organization. All members are expected to devote a great deal of time and energy to church projects and organization, and most do so. The members of Peoples Temple are far more involved in Church activities than are the members of most churches.
I [illegible one-word insertion] have known Timothy O. (“Tim Stoen”) Stoen since 1969 when he joined. At that time there was no member who was an attorney. The church had no regular attorney. Tim was very devoted and immediately assumed that role. He is an extraordinarily hard working person. When he joined he was employed by the Mendocino County Legal Services Foundation and seemed very concerned over the legal needs of the poor. The church had similar concerns, and in fact had assisted him to set up his office, so his involvement in church work appeared to be quite spontaneous.
The church very rapidly grew in size. Tim Stoen’s work and influence in the church grew as the church grew. He assumed full charge of all of the legal affairs of the church and its members, including Jim Jones, the pastor and guiding influence of Peoples Temple since its inception. All legal decisions were left to him. Between 1970 and 1973 our church grew from a small congregation in Redwood Valley, Mendocino County, California to a congregation of well over 16,000 owning churches in redwood Valley, San Francisco and Los Angeles, with members in every major city in California between Ukiah on the north and San Diego on the south, with additional smaller congregations in Philadelphia, PA, Chicago, Ill., and Houston, Tex., and owning in addition four care homes and a number or residences in Mendocino County, a large auxiliary project center in Mendocino County, an 31 unit Apartment house in Los Angeles and a fleet of a11 Greyhound-type buses which made annual and often semi-annual trips around the United States and weekly runs between Mendocino County on the North and Los Angeles County on the south. Periodical publications and regularly scheduled radio broadcasts were produced and solicitation mailers and other publications distributed. A full scale free legal services program was instituted which rendered legal services to more than 100 persons weekly.
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FF-2-15B
Tim Stoen did the legal work on almost all of this entire development. Another attorney Eugene Chaikin joined in 1972 but his role from then till the end of 1973 when he went to Guyana was an assistant to Tim Stoen. Tim Stoen remained the principle [principal] attorney and legal adviser to Peoples Temple till summer of 1977. During his entire membership he had the principle responsibility for all of the legal affairs of the church and was the personal attorney of literally thousands of church members. He was intimately familiar with the total structure of the church and with all of its projects and operations. He served for years as a Director, and Chairman of the board of Directors of Peoples Temple.
[handwritten notation: “O.K E.C 9/5 O.K HT”]
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FF-2-15B (2)
[illegible page]
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FF-2-15C
They believe that service to the Diety can best be expressed by service to ones fellow man, that they must – as a religious-philosophical imperative demonstrate goodness rather than just talking about it, and that this demonstration must be an ongoing part of their everyday lives. In practice this becomes very involved. Jim Jones had proclaimed this before the temple and doing it gave a new meaning to the people’s lives, and so it became a reality. The reality was that one indeed takes people into one’s home, feeds them, clothes them, pays their bills. It becomes ones ongoing responsibility, and with that concept of reality a lot of loyalty is developed.
To finance these ideas becoming institutions, programs like pastry sales and rummage sales were developed, funds solicitated on the streets and in the offices of donors of larger means. These sums went to fund a free legal services program. They went to pay medical fees for those who could not afford adequate medicine. They went to support preventative medical programs for senior and minority groups. They supported a college scholarship program which, at its height supported over 110 students, either part or full time, in colleges and universities, including three students in law school and two in medical school. They supported a program whereby the homes of poor persons who were facing the [Typed insertion: “loss through”] demolition of their homes due to deterioration, had them repaired by a volunteer construction team with materials furnished by the church, all without cost to the recipient. It went to make up mortgage payments for those who were in danger of losing their homes due to financial ill fortune. It went to support other service agencies in the community, including, among others medical clinic and a senior citizens protective service in San Francisco. Hospital visitations and senior care programs were carried on regularly, as were programs for the visitation of persons in jail and in prison. We gave material and financial to the American Indian struggle, a group who have for decades been in the depths of poverty and oppression.
Most members were active in several of these programs. We tried to demonstrate most diligently that we really could be our brother’s keeper.
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FF-2-165A
Rough 9/2 EC
Jack Lovell Beam
Prof: Auto salesman. Member PT since 1949. Known TOS since he joined PT in 1969. When TOS joined there was no attorney that was a member. The church had no regular attorney. TOS seemed very devoted and immediately assumed that role. When he joined he was employed by the Mendocino County Legal Services Foundation and was very concerned over the legal needs of the poor. The church had similar concerns and had assisted him to clean up and arrange his office in Ukiah.
The church very rapidly grew in size. TOS work and influence of the church grew as the church grew. He assumed full charge of all of the legal affairs of the church and its members, including Rev. Jones and my own. He handled my adoption of my daughter Linda Sharon, advised me upon my rest home business and other legal matters.
From 1970 through 1973 our church grew from a small congregation in Redwood Valley California to a congregation of over 10,000 serving churches in Redwood Valley, San Francisco & Los Angeles, and owning, in addition 4 care homes, and a number of residences in Mendocino County, a large auxiliary project structure in Mendocino County, and apartment house in Los Angeles and a fleet of 11 diesel buses, which made annual and often semiannual tours around the entire US. Periodical publications and regularly scheduled radio programs were produced, solicitation mailers and other publications distributed. A full-scale legal services program was instituted
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FF-2-165B
which rendered legal services to more than 100 persons weekly.
TOS did a little work for most of this entire development. Another attorney, Eugene Chaikin, joined mid-1972, but his role from then until December 1973 when he went to Guyana, was as an assistant to TOS. TOS remained the principal attorney and legal advisor to Peoples Temple till spring of 1977, when he resigned. He, during his entire membership, had principal responsibility for all of the legal affairs of the church and was intimately familiar with the total structure and all of the projects of the church.
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FF-2-161A – 161B
Rough 9/2
Rebecca May Beikman – primary school teacher, nurse’s aide
PT since 1953. Known TOS since about 1969 when he joined the church. He was very quickly involved in church affairs and he would often give legal advice in public meetings on church matters. It was known to me as the attorney for PT.
In 1974 I was working at Hacienda Convalescent Hospital in Ukiah & suffered a job related injury. I spoke with TOS about the matter and the possibility of bringing a civil action. We discussed the merits of the case and he gave me legal advice on the case, and he agreed to pursue the matter on my behalf. I met with him at his office in the Ukiah Courthouse and he had me sign some papers that had to do with the case.
I came to Guyana in December of 1974 and have remained in Guyana since that time. I last saw TOS in the spring of 1977 in Jonestown. At that time he told me that he was going to be in Georgetown to take care of legal matters for PT. In public meetings in Jonestown at that time, TOS gave legal advice concerning the purchase of real property in Guyana. During these meetings TOS was often consulted about his legal opinion on a variety of matters, and he gave his legal opinion at such times.
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FF-2-120
Affidavit of Julia Birkley
I am a retired cook. I joined Peoples Temple of the Disciples of Christ (“Peoples Temple,” “the church”) in 1971 and I have known Timothy O. Stoen (“Tim Stoen”) from that time until early 1977. He introduced himself to myself and others as the attorney for the church. He often referred to himself as such in church services.
In 1974 I consulted Tim Stoen about an insurance policy. I received legal advice from him regarding this insurance policy and my financial affairs.
Over the years I often heard Tim Stoen speak in church services at Peoples Temple churches as the attorney for the church and give legal advice and opinions on church affairs.
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FF-2-176A
Rough 9/3 HT
Julia Birkley – retired cook
PT: around 1971. I knew TOS from that time. He introduced himself to myself & others in church services as the attorney for PT.
In 1973 or 1974, I contacted TOS about an insurance policy. I sought his legal advice regarding the policy and he gave me legal advice about it, agreed to pursue the matter for me, & took the necessary information from me.
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FF-2-113
Affidavit of Selika Bordenave
By profession, I am a retired men’s suit inspector. I became a member of Peoples Temple of the Disciples of Christ (“the church,” “Peoples Temple”) in 1972. I met Timothy O. Stoen on July 10, 1972 when I stayed overnight at his house in Redwood Valley. At the time, I had just joined the Temple.
[Handwritten notes: “So what.” “Do not use – no value.” “E.C. agreed”]
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FF-2-179D
Pierre Brian Bouquet, 1975. I was told TOS was the attorney for PT.
Advised me in regards to securing unemployment benefits.
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FF-2-188
Affidavit of Mark Boutte
[Handwritten notation: “Rough JC 9/3”]
By profession, I am a carpenter. I joined Peoples Temple of the Disciples of Christ (“the church”) in 1969 and personally met Timothy O. Stoen in 1975. He said publicly in meetings that we could go to him for legal advice and to meet him in the back of the church after meetings if you wanted to discuss legal matters.
In 1975, he advised me of the best procedures to follow in making a claim in an automobile accident case.
In 1976, I went to him for advice in handling traffic tickets that had been paid but were still being sent to me in the mail.
He advised many young people like myself on how to handle things like probation violations, traffic tickets and arrests for things like petty theft.
[Handwritten notation: “OK EC 9/5 OK HT 9/5”]
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FF-2-179G
Mark Anthony Boutte, carpenter in the milling department, 1969, 1975. He said publicly in meetings that he was a lawyer and to come to the back of the church if you wanted to see him.
In 1975, he advised me on how to handle accident insurance in a car accident I was involved in.
In 1976, on another occasion, he advised me [balance of paragraph illegible]
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FF-2-198
Affidavit of Dorothy Ann Brewer
[Handwritten notation: “Rough [illegible month]/3 JC”]
By profession, I am a teacher and a secretary. I joined Peoples Temple of the Disciples of Christ (“Peoples Temple”) in 1969. It was mentioned in Peoples Temple meetings that members could go to Timothy O. Stoen for free legal advice. I specifically remember being told that in 1972, although it may have been announced in meetings previous to that.
In 1973, he advised me in the transfer of property my husband and I owned. He corresponded with my husband’s lawyer on the matter.
He frequently advised members of the congregation to see him after meetings for legal counseling.
[Handwritten notation: “O.K. E.C. 9/5 OK HT”]
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FF-2-179F
Dorothy Ann Brewer, teacher, 1969, 1972. It was mentioned in PT meetings that members could go to him for legal advice.
In 1973, TOS advised me on the transfer of property my husband & I owned. He corresponded with my husband’s lawyer on the matter.
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FF-2-159A
Rough 9/2 Gene
Terri Buford
I am a graduate of University of Pennsylvania and UC Berkeley in Journalism. I’ve been a member of PT since 1972 and have known TOS since that time. When he first introduced himself to me it was as church attorney and Assistant DA of Mendocino County. I last saw him in Georgetown, Guyana in May of 1977.
In 1972 TOS approached me as the attorney for PT and asked me to do volunteer secretarial work for him. I agreed and he gave me six large paper cartons of legal files (I found another 10 boxes later) all relating to legal matters of the church and various members. I acted as his secretary for about 1 year, working on all types of legal matters for the church and members at his direction. These included church corporate affairs, minutes and tax matters, acquisition of real properties for the church, acceptance and donation of personal and real properties on behalf of the church, writing wills for members with dispositive provisions in favor of the church, letters and documents relating to the Disciples of Christ denomination, many letters on behalf of the church.
After I ceased secretarial activity I served as a sort of liaison between TOS & Rev. Jones with respect to the legal
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FF-2-159B
affairs of the church. One of my jobs on a daily basis was to telephone him, give him a rundown of the legal affairs of the church, and get his opinions, evaluations and suggestions. This continued for 3 years from 1973 to 1977. During this period there was nothing in the PT program that TOS was not consulted about which did not receive his approval.
During those years, though Gene Chaikin and others often did legal work for the church, he was the principal attorney and legal advisor for the church, and all its related activities and organizations.
In February 1977 TOS came to Guyana, South America to do legal work for the Church project there. Among other matters he handled the acquisition of real property in Georgetown. During that time Gene Chaikin and Harriet Tropp came down from USA. Rev. Jones was there and a general legal conference was held. Among other matters discussed was a concern over the reach of “Moonie” conservatorship cases. TOS stated that he had had several discussions with Maria Katsaris concerning her relations with her father, that he
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FF-2-159C
thought she might be a prime case, and had suggested to her that she come down to Guyana to avoid jurisdiction. He stated that he knew Steve Katsaris well, that he had a very hostile attitude towards PT due to his daughter’s involvement, and that he felt S. K. would likely move in that direction.
While in Guyana, he also reviewed the Guyana lease and incorporation papers, negotiating for the purchase of real properties and gave legal advice on variety of topics. He remained in Guyana until [blank line] 1977, when he left the Church.
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FF-2-215
AFFIDAVIT OF MARY CANADA
[Handwritten notation: “Rough 9/2”]
I am a retired person. I became a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) in 1971. I have known Timothy O. Stoen (“Tim Stoen”) from that time until early in 1977. He was introduced to me as the attorney for the church.
Sometime in 1974 I consulted Tim Stoen about my deceased husband’s pension. Tim Stoen gave me his legal opinion that I had several thousands of dollars due to me, and gave me legal advice on the matter. I received legal advice from him on this matter, subsequently, on more than one occasion.
Over the years, Tim Stoen would often speak as the Church attorney, in public meetings and services at the different Peoples Temple churches. He would give legal advice and opinion on church affairs and the legal affairs of individual members.
[O.K. E.C. 9/4 OK HT”]
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FF-2-147B
Rough 9/2 HT
1. Mary F. Canada – retired person
PT member since 1971 – knew TOS from that time. He was introduced to me as attorney for the church.
2. Around 1974 I saw TOS after a service in Redwood Valley and asked his advice about my deceased husband’s pension – as I had not been getting the benefits. TOS advised that I had several thousands of dollars coming to me, and gave me advice on the matter. I spoke with him about this matter subsequently on more than one occasion.
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FF-2-20
Affidavit of Jeffrey James Carey
[handwritten notation: “Rough HT 9/3”}
By profession I am a cook. I have been a member of Peoples Temple of the Disciples of Christ (“the church,” “Peoples Temple”) since August of 1969. I have known Timothy O. Stoen (“Tim Stoen”)] since that time until Spring of 1977, at Jonestown, in the Northwest District of Guyana, South America.
In 1973 Tim Stoen gave me legal advice concerning a criminal matter. In addition, in 1972 I was concerned with my father’s feeling about me participation in the church (I was 19 years old) and I discussed the matter with Tim Stoen. He telephoned my father who was then a resident of Mangilao, Guam, and satisfied him as to the church, and arranged his consent for a church member, Jack Beam, to be my guardian to establish my residence for college tuition purposes. Until I came to Guyana in 1974 where I have been ever since. I worked in the church publications department evenings and weekends. I would run errands for Tim Stoen and routinely took all publications to him for “legal clearance.” He would normally review them in my presence, correct and delete in his own hand, and initial “T.O.S”, and return them to me to take back to the publications department. I would also routinely take legal documents to him, for his review; I would take several files of such documents to Tim Stoen each week which he would at times review in my presence.
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FF-2-176B & C
Jeffrey James Carey
Profession: Cook
Member since August 1969.
Knew TOS from that date till spring ‘77 at Jonestown, NWD, Guyana.
Consult: Gave legal advice concerning a criminal matter in, I believe, 1973.
Also, in 1972, I was concerned with my father’s feeling about my participation in church (I was then 19 years old) and discussed the matter with TOS. He telephoned my father who was then a resident of Mangilao, Guam, and satisfied him as to the church and arranged his consent for a church member, Jack Beam, to be my guardian to establish my residence for college tuition purposes.
Until I came to Guyana in 1974, I worked in the church publications department evenings and weekends. I would run errands for him and routinely took all publications to him for “legal clearance,” he would normally review them in my presence, correct and delete in his own hand, and initial “TOS” and return them to me to take back. I would also routinely take legal documents for his review and would take several piles of to him each week which he would at times review in my presence.
While TOS was in Jonestown in 1977 he was studying Commonwealth law so he could pass the bar in Guyana in order to represent PT and its members in Guyana. I used to help him with his studying in the evenings. We had several business meetings which both he and I attended where he gave legal advice on various matters. He also did legal work on 2 real estate transactions, 2 sales fraud cases over 2 shortages in a lumber purchase where he advised me on how to act and what to say to the seller, one Mr. Baccus, and was present at a meeting with him where he presented himself as the attorney for PT and negotiated with the man, and on several tax matters. He also discussed the matter of the custody of John Stoen, and advised how he would assist keeping the child in Guyana.
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FF-2-115
Affidavit of Ruby Carroll
I am a seamstress. In 1969, I joined Peoples Temple of the Disciples of Christ and one year later was introduced to Timothy O. Stoen as the Temple’s legal counsel.
In 1975, he advised me in a civil suit I was bringing.
Around 1970, he drew up guardianship papers for my son, John Gardner.
[Handwritten addition: “He also advised me from time to time about various legal affairs of my children and their companions.”]
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FF-2-206A
Affidavit of Walter Cartmell
I am a finished-cabinet maker and a construction worker. I joined Peoples Temple of the Disciples of Christ in 1958, and I met Timothy O. Stoen in 1970 shortly after he became a member of the Temple in Redwood Valley, Ca. [Question mark in margin]
In 1975, I started the process of adoption of my son, Tyrone Cartmell, which was later completed by other lawyers. He also advised my wife Patti on a number of occasions from 1970 until 1977.
[Handwritten notation: “OK EC 9/4”]
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FF-2-114
Affidavit of Maryann Scheid Casanova
My profession I am a medical assistant. I have been a member of Peoples Temple of the Disciples of Christ since about 1971, and I have known Timothy O. Stoen (“Tim Stoen”) from that time until 1977.
Sometime in 1973 or 1974 I spoke with Tim Stoen about the custody of my child Sophia. Tim Stoen gave me legal advice on what I should do.
In 1974 I received Tim Stoen’s legal advice about my husband’s failure to pay child support. He got copies of my husband’s divorce decree, and he gave me legal advice on what I should do, on several occasions. Sometime in 1975 Tim Stoen again gave me legal advice about my status as a welfare recipient, and the payment of child support. Tim Stoen dictated a letter for me to send to my brother’s attorney in Beverly Hills, California, as my ex-husband was making the child support payments to him.
In 1973 I participated in a picket line around the San Francisco Examiner Building organized by Peoples Temple. Tim Stoen was present and gave legal advice concerning the conduct of the picket line. Tim Stoen also spoke to policemen there, and identified himself as the attorney for Peoples Temple.
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FF-2-174
Rough 9/3 HT
Maryann Scheid Casanova – medical assistant
PT – since about 1971. Known TOS since that time. He was referred to me as the church’s attorney.
Around 1973 or 1974 I spoke with TOS regarding the custody of my child Sophia. He advised me on how to proceed. Again, around 1974 I sought TOS’s advice regarding my husband’s failure to pay child support. He gave me legal advice on what to do and get copies of my husband’s divorce decree. He talked with me on several occasions about this matter, and eventually the matter was taken to court. On another occasion, sometime in 1975, I spoke with TOS regarding my welfare status and the payment of child support. TOS dictated a letter to me to send to my brother’s attorney in Beverly Hills, California, which I did send.
In 1973, I participated in a picket line around the San Francisco Examiner Building on Mission St. in San Francisco. TOS was present and gave advice concerning the conduct of the picket line. He also spoke to policemen and other city officials there and identified himself as attorney for PT.
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FF-2-9A
Affidavit of Eugene Chaikin: [handwritten insertion: “Ok HT”]
As I recall now, the first time I attended Peoples Temple of the Disciples of Christ (“Peoples Temple”, the “the church”) was in January of 1972 at a meeting in Redwood Valley, California which is in Mendocino County about 20 miles north of Ukiah. At that time, having been an attorney licensed in the state of California for over 10 years, I was employed by Shasta County as Deputy County Counsel. Some of the first persons I met upon going to church were Timothy O. Stoen (“Tim Stoen” or “Tim”) and his then wife Grace. Timothy introduced himself as Chairman of the Board and Attorney for the church, as well as Assistant District Attorney for Mendocino County in charge of civil matters – a position roughly equivalent to the one that I held in Shasta County at the time. I was very impressed with Tim and his dedication to the church and to Reverend Jones. We had a lot in common in terms of our jobs. He was very instrumental in impressing me with the ideals and value of the church. I continued to live and work in Shasta County, but attend[ed] church frequently in Mendocino county. The person I dealt with more than anyone else was Tim Stoen. He functioned as chief legal counsel for the church and I acted as his assistant, principally doing free legal work for indigent persons in the church free legal services program.
During the summer of 1972 I gave up my job in Shasta County, and my family and I moved to Redwood Valley where I began to work on church affairs, mostly free legal services on a non-compensated full time basis. One exception to the statement that I was not very involved in church organization legal work was in the area of real estate where I worked with Tim because I had a heavy real estate background. The church was growing very rapidly, there were lots of new members and it seemed that they all had legal problems. Tim continued to do the bulk of the church legal work, and to supervise me in the legal services program. He appeared to be one of the hardest working lawyers I have ever met. This relationship continued until December 31, 1973 when I went to Guyana to set up the church mission program there.
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FF-2-9B
I remained in Guyana, South America until July 31, 1975, when I returned to work with the church in the U.S.A. During the time I was in Guyana Tim worked as the sole legal counsel for Peoples Temple, taking care of all matters. On my return to the States I again began to work under Tim Stoen as counsel for the church and worked in that position under Tim until the late spring or early summer of 1977 when he severed his connection with the church.
During the time that I worked with Tim Stoen beginning in 1972, we handled many real estate transactions for the church, including the purchase of church properties in Mendocino County, San Francisco County and Los Angeles County. He organized and set up bank accounts for the church and was personally responsible for handling church funds and, in addition, funds of some individual members of the church in an individual capacity. He wrote several revisions of the Articles of Incorporation and of the Bylaws (which I also worked on) which encompassed a reorganization of the entire church structure. He continuously acted as the counsel for the church and representative of the church with the denomination, the Christian church (Disciples of Christ). In this regard he contacted attorneys for the Disciples of Christ, attended meetings and conferences, wrote numerous letters and in other ways represented the church as attorney. There were several lawsuits filed against the church over the years. In each case Tim either represented the church, or selected outside counsel and supervised him for the church. I recall one rather lengthy suit involving a dispute over real property the church had purchased in Mendocino County which Tim handled alone for the church.
As part of the church activities there was a so-called governmental, or organizational meeting of some principal members of the church at least once every two weeks and usually more frequently. The Board usually ratified decisions made informally in these meetings. These meetings continued, from my knowledge, from the summer of 1973 through the summer of 1978. Tim attended the meetings regularly till he went to Guyana in February of 1977, and in almost every meeting gave legal advice concerning matters that were broached that had legal implications.
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FF-2-9C
As a result of these activities he became intimately familiar with all of the affairs, corporate, financial, religious and otherwise of the church structure. It is difficult to imagine any other person in the entire organization of this large church, which by the end of 1973 had some 20,000 members, maintained three independent church structures with three independent congregations, maintained a fleet of 11 Greyhound-type busses which it serviced itself and regularly moved that caravan all over California and annually across the United States – who was more intimately familiar with all of the affairs of the church than Timothy O. Stoen. He seemed one of the most dedicated persons I have ever met – his life was his job and the church. He hardly took out time to eat and sleep. I suppose that his position can best expressed by the office that he held for a number of years – Chairman of the Board of Directors, and Chief Legal Counsel.
Added Paragraph
He gave legal advice to the Board of Directors, the Officers and the Pastoral staff of the Church. He wrote numerous letters to various persons with respect to the legal activities of the church. He filed tax returns with the State of California and exemption certificates with several counties. He gave legal advice concerning acceptance of donations for members. Among others was a donation of two places of real property in Los Angeles County by Wade and Mable Medlock. He drew a huge variety of legal forms used by various church departments and programs, including the Guyana project. He wrote wills with dispositive provisions in favor of the church, drew gift deeds and other documents. He gave legal advice to literally thousands of church members. As a result of participating in the church legal services program he became intimately familiar with the lives of hundreds of church members.
Tim was especially close to persons who had more intimate organizational connections with the church. An example is Maria Katsaris, whose case he discussed in detail in my presence a number of times – both in the U.S and later,
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FF-2-9D
in Guyana in April, 1977.
During the latter part of 1975, 1976, and early 1977 there was a law office established on the premises of the San Francisco Church. There were a number of persons who worked together there handling church business and also handling clients affairs as part of the legal services program. Among others were myself, June Crym, Harriet Tropp (who was then a law student), Bea Orsot and several others. Weekly meetings were held similar to meetings in any law firm where files were reviewed and significant business discussed. Tim presided over those meetings as chief counsel in the discussions, drafted documents, delt with transactions and worked with the cases, as did the others.
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FF-2-9E
Addition to Chaikin Affidavit:
The Guyana meeting occurs as follows: On or about April 23, 1977 at the San Francisco church we received a message from Tim Stoen requesting that Harriet Tropp and I come to Guyana for a legal conference. We were to drop everything and come at once. We did so and arrived in Georgetown, Guyana, as reflected by the date stamp on my passport, on April 27, 1977. We went at once to the house kept by the People’s Temple Guyana organization at 4 Lamaha Gardens, Georgetown and began a conference that continued until May 1, 1977 when, again according to the date stamp on my passport, we returned to the U.S.A. The conference lasted over 60 hours, allowing only time for some sleep. It took place in the large master bedroom in the rear of the dwelling. Present were Carolyn Layton Prokes, Terri Buford, Timothy O. Stoen, Jim Jones, Harriet Tropp and myself. Marceline Jones, wife of Jim Jones for __ years, was there from time to time.
Several subjects were discussed in detail. Among those was the risk that conservatorships might be attempted against some of the members and strategies to avoid them. Individual cases were discussed. In particular we discussed Maria Katsaris case. I can recall Tim Stoen saying that her father Steve Katsaris was an evil man, very dangerous to the church; that he was very hostile and would stoop to any level; that he was a “no good bastard” or words to that effect. He told us that Maria had told him in detail about how her father had molested her, that he personally had reviewed the facts and believed that Maria was telling the truth. He advised that he suggest to her that she come to Guyana to avoid the jurisdiction of the court; that if that were not immediately possible she should stay away from her father altogether but should write “nice” letters to him to mollify him. He also suggested that she disclose the facts that he had molested her feeling that such disclosure would deter her father from further pursuit of her.
—–
FF-2-140A
Joicy Clark – retired domestic
PT around 1969. I knew TOS from that time. I was introduced to TOS as the church attorney.
Around 1973 I asked TOS’s advice about an insurance policy I was paying premiums on. He read the policy and gave me legal advice on how to get the most benefits.
In 1976 I had an accident on a bus. In the fall of 1976 I contacted TOS about whether or not I should accept a settlement offer. He asked me about the accident and we discussed the case. He looked over the offer and gave me his legal opinion that I should accept the offer, based on our discussion of the case.
——
FF-2-26A – 26B
Affidavit of Elois Christine Young, formerly Elois Christine Cobb: (1 of 2)
I am a licensed vocational nurse. I have been a member of Peoples Temple of the Disciples of Christ (“the church,” “Peoples Temple”) since 1956 and have known Timothy O. Stoen (“Tim Stoen,” “Tim”) since 1969. He acted as my lawyer on several occasions.
In about 1970 I began to divorce my then husband James Cobb and retained Tim Stoen for that purpose. Although another attorney completed the matter, Tim instructed me and several of my children on how to testify in court, and had a number of church members come to court to give moral support.
During the years 1970 to 1973 my son Jim Cobb was a student being supported in school by Peoples Temple. His politics were extremely radical. At times he caused difficulty for the church by talking violence and Tim spoke to him about this several times. In mid-1973 Jim Cobb, with several other young church members, left the church carrying with them a considerable quantity of guns and ammunition, saying he intended to form a rural guerrilla band.
At that time I, with several others in the church, consulted with Tim with respect to our legal position, the position of the church (lest it become involved), the position of Tom Rice from whom they took a rifle, and the position of Jim Cobb himself, hoping to prevent him and the other young people from doing something foolish. Tim Stoen spent hours with us advising and working out arrangements to help protect all concerned. Under his advice a report of the incident was made to the Sheriff’s Department.
A couple of years later, when Jim Cobb began systematically contacting people and making derogatory statements about the church and its members, I frequently consulted with Tim Stoen on how best to handle the situation to protect the good name of the church against Jim Cobb’s attacks. During those meetings Tim frequently told me that I should be careful in any dealings with my son Jim, that he was an incorrigible liar and that I should not believe anything he might say to me. He told me many times that my son Jim was saying many totally false and vicious things about the church, Reverend Jones, and several members. This is the same Jim Cobb that he is now representing in a lawsuit against Peoples Temple [struck-out text: “for defamation, among other things.”]
From time to time I was harassed by my ex-husband James and I consulted with Tim when these episodes occurred. He also assisted me in a bankruptcy proceeding, and gave me advice on a probate proceeding in which I was an heir, as well as other legal advice. He never charged me, or any church member to my knowledge for legal work.
On August 1, 1976 he performed the marriage ceremony between myself and my present husband. (He was also a minister in the church ordained by the Disciples of Christ.) We were rather close friends, as well as co-workers in the church
[handwritten insertion: “Additionally, he was”] my attorney down through the years.
I last saw him in church in February of 1977 when he told the congregation that he was going to Guyana to work with the church there.
——
FF-2-166A & B
Rough 9/2 EC
Elois Christine Young:
Prof: Licensed vocational nurse. Member PT 1956. Knew TOS since he joined in 1969.
In about 1970 I began to divorce my then-husband James Cobb and retained TOS for that purpose. He instructed me and several of my children on how to testify in court, and had a number of church members go to court with us to give us moral support. Another attorney completed the divorce. During those years my son Jim Cobb was a student being supported in school by the Church. At times he caused difficulties for the church by advocating violence and Tim Stoen spoke to him about this several times. After Jim Cobb left in 1973 carrying with him a considerable quantity of guns and ammunition [marginal notation “?”] and saying he (with friends) intended to form a rural guerrilla band, I with many others in the church consulted with TOS with respect to our legal position, the position of the church (least [lest] it become involved), the position of Tom Kice from whom they took a rifle, and the position of Jim Cobb himself – hoping to prevent him and his friends from doing something foolish. TOS spent hours with us in advising and working out arrangements to help protect all concerned. A couple of years later, when Jim Cobb began systematically contacting people and making derogatory statements about the Church and its members, I frequently consulted with TOS on how best to handle the situation to protect the good name of the church against Jim Cobb’s attacks.
During those meetings TOS frequently told me that I should be careful in any dealings with my son Jim, that Jim was an incorrigible liar and that I should not believe anything that he should say to me. He told me several times that my son Jim was saying many totally false and vicious things about the church, Rev. Jones and several members. This is the same Jim Cobb that he is now representing in a lawsuit against Peoples Temple.
From time to time I was harassed by my ex-husband James and I consulted with TOS when these episodes occurred. He also assisted me in a bankruptcy proceeding. He also gave me some advice on the probate proceeding in which I was an heir, and miscellaneous legal advice.
[Words deleted: “I last saw TOS “] On August 1, 1976 when he performed the marriage ceremony at my marriage with my present husband. We were rather close friends, as well as coworkers in the church and as well as he being my attorney down through the years. I last saw him in church in San Francisco in about February of 1977 when he told the congregation he was coming to Guyana.
——
FF-2-233
Handwritten note by Christine Cobb Young
I filed for divorce with Timothy Stoen. I did not want to ask my ex-husband for alimony and Tim Stoen asked for more alimony than Jim Cobb could afford, so Cobb’s lawyer wrote to Tim. The only thing is the lawyer following Tim finished the legal work.
My mother left a grocery store & other property when she died, he gave me legal advice how to get my share of the money.
All of this however has been several years ago, seven or more years.
Christine Young
——
FF2-244
Affidavit of Inez Conedy
I am a retired nurse. I joined Peoples Temple of the Disciples of Christ in 1971. I needed to see an attorney and was referred to Timothy O. Stoen who introduced himself as the attorney for the Temple.
In the fall of 1971 or 1972, I consulted Mr. Stoen about real property I had inherited.
Again in 1973 or 1974, he gave me legal advice concerning a car accident I was involved in.
Over the years, in my presence or to my knowledge, he advised and assisted literally hundreds of members of Peoples Temple.
—–
FF-2-179B
Inez Conedy. Nurse, 1971, 1971. I needed to see an attorney. I was referred to TOS. He was introduced to me as the attorney for Peoples Temple.
In the fall of 1971 or early 1972, I consulted TOS about real property I had inherited.
Again in 1973 or 1974, he gave me legal advice concerning a car accident I was involved in.
——
FF-2-129
Affidavit of Barbara Cordell
I am a preschool teacher’s aide and a housewife. I have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1968. I have known Timothy O. Stoen (Tim Stoen) since he joined the church, in about 1969, until early in 1977. As I recall, not long after he became a member he became the attorney for Peoples Temple, and represented himself as such.
In June of 1974 I spoke with him about obtaining guardianship over a child I was caring for. He gave me legal advice regarding this, and directed June Crym, a legal secretary and member of the church, to draw up guardianship papers on my behalf. He was with me at the court hearing in San Francisco, and advised me on what to say to the judge.
I attended business meetings of Peoples Temple from May of 1973 until sometime in 1977. Tim Stoen also participated. He attended most meetings until he left for Guyana in February 1977. At each meeting, Tim Stoen would be called upon to give, and would give, legal advice and opinions regarding church affairs, including the purchase and sale of real property, corporate matters, publications and radio broadcasts, public relations, motor vehicle matters, and other church business. Even if he were not present, if a legal opinion were called for, he would be telephoned from the meeting, and asked his opinion.
——
FF-2-140B
[Handwritten note: “Rough 9/2”]
Barbara Cordell – Professor, child care
PT member since 1968. I knew TOS since he joined the church around 1969. Soon thereafter he moved to Redwood Valley and he represented himself as attorney for the church.
In June 1974 I spoke with him about obtaining guardianship over Jameel Lawrence. He discussed the procedure with me and gave me legal advice. He directed June Crym, a legal secretary who was a member of the church, to draw up guardianship papers on my behalf. Although I represented myself in the court hearing, he met me at the courthouse in San Francisco and advised me on what to say in the court hearing. He was with me at the hearing.
I was on the Government Board of PT since May of 1973. Tim Stoen was also on that Board which met weekly. At each meeting, TOS would be called upon to give and would give legal advice regarding church affairs, including the purchase & sale of real property, corporate matters, public relations and other matters. If a legal opinion was asked for, Tim Stoen would be consulted.
——
FF-2-175B
Edith Extell Cordell
Profession: Retired
Member of PT since 1951
Known TOS since he joined in Redwood Valley.
Consultant about Guardianship of a child I had in my custody in 1974.
——
FF-2-11A
Affidavit of Harold Cordell:
I am at present 41 years of age. I have been an active member of Peoples Temple (originally a predecessor organization to plaintiff (“the church,” “Peoples Temple”) since 1955. I work as a bookkeeper and cost accountant. I have worked on the books and records of Peoples Temple since 1971 as a part time volunteer worker, and on a full time basis since about March of 1975.
I have known Timothy O. Stoen since 1969 or early 1970 when he joined the church. Shortly after he became a member he became very active in the central organizational structure because of his legal background and qualifications. He was the only attorney of the church for all tax and corporate functions, and all business functions till summer of 1972 when Gene Chaikin began to assist him, and again during the whole of 1974 and the first 8 months of 1975 when Gene Chaikin was in Guyana. Until the early part of 197[last digit of year illegible], during those times when Gene Chaikin was active in church affairs in the United States, Tim Stoen acted as senior counsel. As such he was acquainted with and participated in all aspects Peoples Temple activities programs.
I can recall being advised by Tim, and working with him: on tax matters including Church tax returns during the years 1973, 1974, and 1975; with respect to corporate and financial affairs during 1973, 1974, 1975, and 1976; with respect to church which he regularly reviewed and approved during 9173, 1974, 1975, and 1976; with respect to tax returns I or members which we did on a volunteer basis during the same years; with respect to the management of church owned real properties during 1973, 1974, and 1975. During these years he either handled himself or supervised outside counsel in handling all church litigation (there were several cases) and all claims made against the church.
During the years 1973, 1974, 1975, and 1976, to my knowledge as an attorney he spent at least 20 hours per week working on church legal affairs. Next to Rev. Jones he was the single person most acquainted with the total program of the Peoples Temple Church because he would give “legal clearance” on every proposed program and periodic “legal review” of every active church program.
—–
FF-2-11B
During the years of 1970 through 1976 he was usually available before, during, and after church services (Sundays, Saturday nights, and Wednesday nights) to give free legal counsel and assistance to all persons who attended church and might desire such. In this function he became intimately acquainted with the confidential affairs of almost all of the active membership of the Church, and also hundreds of more casual members.
[Deleted paragraph: “All references in this affidavit to Tim or Tim Stoen refer to the defendant Timothy O. Stoen. All references to “church,” “the church,” “Peoples Temple” refer to the plaintiff Peoples Temple of the Disciples of Christ, a California corporation.”]
—–
FF-2-135A – 135B
Handwritten notes by Eugene Chaikin for affidavit by Harold Cordell]
Harold Cordell (41 years of age)
Background: Active with Peoples Temple since 1955. Trained to do cost accounting. Worked with books and records of Peoples Temple since 1971, as a part-time volunteer function, and already full-time basis since about March of 1975.
I have known Tim Stoen since 1970. Shortly after he became a member he became active in the central organizational structure because of his legal background and qualifications. He was the only attorney for the church for all tax and corporate functions till June or July of 1972, when Gene Chaikin began to help, and again from December 1973 to August 1975 while Gene Chaikin was in Guyana. Until 1976, during the period when Gene Chaikin was active in church affairs in the US, Stoen acted as senior counsel. As such, he was acquainted with and participated in all church legal problems.
I can recall being advised by him and working with him in: 1) church tax returns during 1973, 1974 & 1975; 2) with respect to corporate and financial affairs during 1973, 1974, 1975, & 1976; 3) with respect to church insurance which he reviewed and approved during 1973, 1974, 1975, 1976; 4) with regard to tax returns for individual members which we did on a volunteer basis during the same years; 5) with respect to the management of church-owned real estate during 1973, 1974 & 1975; 6) during those years he either handled or supervised all church litigation and any claims made against the church.
During the years 1972, 1973, 1974, 1975, 1976, to my knowledge, as an attorney, he spent at least 20 hours per week. Next to Rev. Jones, he was the single person most acquainted with the total program of Peoples Temple Church because he would give “legal clearance” on every proposed program & periodic “legal review” of every active church program.
During the years 1970-1976, he was usually available before, during and after church services (Sundays, Saturday nights, & Wednesday nights) to give free legal counsel and assistance to all persons who attended church and might desire such. In this function he became intimately acquainted with the confidential affairs of almost all of the active membership of the Church, and also of hundreds of more casual members.
——
FF-2-187
Affidavit of Loretta Cordell
[Handwritten notation: “Rough 8/3 J.C.]
I am a secretary stenographer. I have been a member of Peoples Temple [handwritten insertion: originally a predecessororganization to PT, (“The Temple”) since 1953. I met Tim Stoen in 1970 shortly after he joined the organization. At that time he frequently referred to himself as the lawyer for the Temple.
In May 1976, Tim advised Annette Jones and I in the matter of securing parental consent for Monique Bacon (Annette’s granddaughter) to travel to Guyana with us.
[Handwritten notation: “OK EC 9/5 OK HT”]
—–
FF-2-179D
Loretta Cordell, Secretary – stenographer, 1953, 1970.
In May 1977 TOS advised Annette Jones in the matter of seeking parental consent for Monique Bacon for consent to leave the country.
——
FF-2-148B
Rough 9/2 HT
1. Teresa Cordell – I am an agricultural worker. PT since 1971. Known TOS since that time. He was introduced to me as the church attorney.
2. In 1975 my mother who is not a member was causing me problems, trying to prevent me from attending church. I sought & received advice from TOS on having a member of the church become my guardian. He gave me advice on guardianship & how to proceed.
In 1976 I was taking care of a baby and I asked him advice on adoption, which he gave. He drew up a power of attorney, making me attorney-in-fact for the child.
——
FF-2-202
AFFIDAVIT OF MILLIE CUNNINGHAM
[Handwritten notation: “Rough 9/2”]
I am a retired domestic worker. I joined Peoples Temple of the Disciples of Christ (“the church, Peoples Temple”) in 1971. I have known Timothy O. Stoen from that time, until Feb of 1977. I was introduced to Tim Stoen as the attorney for Peoples Temple, and I heard him so introduce himself in that fashion on numerous occasions in and out of Church.
In 1972 I was injured in a car accident. I went to Tim Stoen’s office in Ukiah, California and we discussed the case. He said I should bring suit and he agreed to handle the case for me. At that time he had me sign some papers. I spoke with him periodically after that about the case. He wrote a letter on my behalf. In 1973, Tim Stoen advised me not to take the first settlement offer, but later that year, he advised me to accept another settlement offer, which I did. He did not charge me any money.
Over the years, while in church services or meetings in Peoples Temple churches, I have heard Tim Stoen frequently give legal advice and opinions, as the church attorney, about church affairs and the legal affairs of various members.
[Handwritten notation: “OK E.C. 9/5 OK HT”]
—–
FF-2-139A
Millie Cunningham retired domestic
PT 1971 – I knew TOS since that time. I was referred to TOS as an attorney for PT. In 1972 I was injured in a car accident. I went to TOS’s office in Ukiah and spoke with him about the accident. We discussed the merits of the case and he agreed to handle the case for me. At that time he had me sign some papers. I saw him several times after that about the case. One time he told me that he had written a letter on my behalf. Sometime in 1973 TOS advised me not to take the first settlement offer, but later in 1973 TOS advised me to take another settlement offer, which I did.
——
FF-2-210
[Handwritten notation: “Rough JC 9/3”]
Affidavit of Velma Darnes
By profession I am a nurse’s aide. I joined plaintiff Peoples Temple of the Disciples of Christ a Cal Corp (“Peoples Temple”) in 1971; in the same year Timothy O. Stoen was introduced to me as the attorney for Peoples Temple.
In 1973, I was injured on the job and Mr. Stoen advised me to bring an action to recover damages. In 1972, I had received legal advice from Mr. Stoen concerning a divorce. Again in 1972, I consulted him in the purchase of real estate.
[Handwritten notation: “O.K. EC 9/4 OK illegible”]
—–
FF-2-106
Affidavit of Frances B. Davis
I am a housewife. I have been a member of Peoples Temple of the Disciples of Christ since 1972. I have known Timothy O. Stoen since then; he was introduced to me as the attorney for the church.
My husband and I received legal advice from Timothy O. Stoen about a pension fund problem in 1975. He gave legal advice to many members of the church, often after church services.
——
FF-2-175A
Frances B. Davis
Profession: Housewife
Member since 1973.
Knew Stoen since then, introduced as church attorney.
My husband consulted TOS about a pension fund problem in 1975.
——
FF-2-176B & C
Lovie de Pina
Profession: retired housewife, first joined 1972, first met TOS soon after, introduced as the church lawyer. [Illegible sentence] Stayed at his home as a helper to take care of the baby.
Consulted him in 1973 with respect to a domestic relations problem.
——
FF-2-192
Affidavit of Burger Lee Dean
I am a retired housewife. I joined Peoples Temple of the Disciples of Christ (“the church”) in 1972 and have known Timothy O. Stoen since then when he was introduced as the church attorney.
He would see people after church services. Over the years, I saw him about a criminal charge pending against my grandson, Michael and a disability case.
He made himself available to many meters of the Temple as he announced frequently after meetings that he would counsel people on legal affairs and I remember seeing the line waiting to talk to him.
[Handwritten notation: “OK EC 9/5 OK HT”]
—–
FF-2-178
Burger Lee Dean
Profession: Retired housewife. Joined PT in 1972. Knew TOS since then. He was introduced as the church attorney.
He would see people after church services. Over the years I saw him about a criminal charge against my grandson Michael and a disability case.
——
FF-2-194
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF VIOLATT ESTHER DILLARD.
By profession I am a nurses aide. I have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1970, and I have known Timothy O. Stoen (“Tim Stoen”) since that time, until sometime in 1977. He introduced himself in church services on many occasions as the attorney for Peoples Temple.
In 1971 I spoke with Tim Stoen after a church service in Redwood Valley about my daughter, Claudia Norris who was then in the Youth Guidance Center in San Francisco. Tim Stoen gave me legal advice at that time, and dictated a letter for me to send to the Welfare Department in San Jose, California about her case. I discussed with him on more than one occasion thereafter, alternative legal courses of action to take.
In 1974 I suffered a job related injury. I went to Tim Stoen and we discussed the details of the accident and Tim Stoen gave me legal advice on how to proceed so that I would receive my proper benefits. During the next few years we talked about the case periodically and he advised me on each occasion as to what legal steps I should take. The last time I recall discussing this injury case with Tim Stoen was in the middle of 1976, when I gave him copies of all the papers I had relating to the case, dating from 1974 on. Tim Stoen said he would review the papers and discuss my case with the attorney from my union (Local 250). He never charged me for any services, in keeping with church policy.
Frequently, in church services and meetings of Peoples Temple, I have heard Tim Stoen give legal advice on church affairs, speaking as the attorney for Peoples Temple, as well as give advice to individual members.
[Handwritten notation: “OK EC 9/5 OK HT”]
—–
FF-2-139A
Violatt Esther Dillard, nurse’s aide
[Handwritten note: “Rough 9/2 HT”]
PT 1970 – knew TOS since that time.
He introduced himself in church services on many occasions as the attorney for Peoples Temple.
In 1971 I spoke with TOS after a church service in Redwood Valley about my daughter Claudia Norris who was then in Youth Guidance Center in San Francisco. TOS gave me legal advice about how to proceed so as to best protect my daughter’s interest. He dictated a letter for me to send to the Welfare Department in San Jose about her case. I talked with him subsequently on more than one occasion about this matter and discussed the alternative courses of action [to] take.
In 1974 I had a job related accident. I went to TOS and discussed with him the details of the case and TOS gave me legal advice on how to proceed to see that I received my proper benefits. During the next few years I discussed the case with him periodically and he advised me on each occasion as to what legal steps I should take. The last time I recall discussing the case with TOS was in the middle of 1976, when I gave him copies of all the papers I had relating to the matter dated from 1974 on. TOS said he would review the papers and discuss my case with the attorney from my union (Local 250).
—–
FF-2-116
Affidavit of Exia Marie Duckett
I have been a member of Peoples Temple of the Disciples of Christ since 1972, and I have known Timothy O. Stoen (“Tim Stoen”) since that time. He was introduced to me as the church attorney.
In 1972 I consulted Tim Stoen about my prior narcotics and other convictions. In 1973 he gave me legal advice about a welfare problem, and in 1975, in December, he gave me legal advice about a problem involving an automobile accident.
[Handwritten addition: “The church was very successful in rehabilitating me, and a number of others addicted to drugs. A major TV network did a story about it, and Tim Stoen spent time with me, preparing me to do the TV story.”]
——
FF-2-175C
Exia Marie Duckett a.k.a. Marie Lawrence
Prof: none. Member since 1972. Known TOS from that time, introduced as church attorney.
Consult: In 1972 about my prior narcotics and other convictions. In 1973 about a welfare problem & he advised on how to handle it. In 1975, December, about a problem involving an automobile purchase
——
FF-2-131
Affidavit of Irene Edwards
I am a cook. I have been a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) since 1970. I knew Timothy O. Stoen was the attorney as he had publicly announced in church services that he was the attorney for the Temple.
In 1973, Tim Stoen came to me and my husband and gave us legal advice on some property we were thinking of purchasing, and also advised us on the operation of our care home.
In 1977, Tim, my husband and I traveled from Georgetown to Jonestown, Guyana together. We had numerous conversations at that time and we became close friends.
——
FF-2-179G
Irene Edwards, Cook, 1970, 1970. I knew he was the attorney for PT and several members had told me that he was.
In 1970, he advised me to sell my house.
—–
FF-2-179E
Zipporah Edwards – merchandise inspector, 1957, 1971, TOS introduced himself as the attorney for PT.
In 1973, he acted as my attorney in the transference of property in Redwood Valley, California.
——
FF-2-209
AFFIDAVIT OF MARSHALL FARRIS
I am a retired warehouseman. I have been a member of plaintiff Peoples Temple of the Disciples of Christ, a Cal. Corp (“The Church”) since February, 1970. I have known Timothy O. Stoen (“Tim Stoen”) from about that time until about January 1977. I heard that he was the attorney for the church from other members and he was introduced to me as such.
In the fall of 1970 I had an accident and lost time on my job. The owner for the boat where I had the accident refused to pay me any compensation. Tim Stoen discussed the case with me and gave me legal advice and referred me to another lawyer in San Francisco.
Tim Stoen gave legal advice and opinions as the attorney for the Church on church affairs as well as legal affairs of individual members. I heard him do so in church services held at the churches over the years.
[Handwritten notation: “OK EC 9/4 OK HT”]
—–
FF-2-171A
Rough 9/3 HT
Marshall Farris – retired warehouseman
PT – February 1970 – I knew TOS since that time. He was introduced to me as attorney for Peoples Temple.
In the fall of 1970 I had an accident and lost time on my job. The owner of the boat where I had my accident refused to pay me any compensation. I talked with TOS about it and he gave me legal advice about what I could do to get some money from the man, and referred me to a lawyer in San Francisco named Jerry Green.
——
FF-2-179F
Casey Finney, student, 1973, 1973. He publicly announced in [illegible word] that if anyone had legal problems they should contact him.
In 1975, I wanted to move from LA to San Francisco though I was under age at the time, and TOS advised my grandmother, in my presence, how to do this.
My grandmother, Alice Finney, and I stayed at TOS’ house in Redwood Valley in 1975.
——
FF-2-133
Affidavit of Thomas B. Fitch
By profession I am a welder. I have been a member of Peoples Temple of the Disciples of Christ (“the church,” ”Peoples Temple”) since February 1973, and I have known Timothy O. Stoen (Tim Stoen) since that time until 1977.
In September 1974 I was involved in an automobile accident. Tim Stoen gave me legal advice and opinions on my legal position, and what I should do about the matter. He drew up a statement for me to sign about the accident, which I did sign.
Frequently over the years, Tim Stoen, speaking as attorney for Peoples Temple in public church services and meetings at the various Peoples Temple churches, gave legal advice and opinions about church affairs, in addition to advising individual church members about their legal affairs.
——
FF-2-146B
Thomas R. Fitch – welder
Rough 9/2 HT
1. PT – February 1973 – TOS since that time. He introduced himself to me as attorney for Peoples Temple.
2. I had an auto accident September 1974 in San Francisco. I saw TOS in San Francisco and asked his legal advice on what my liabilities were and now to proceed. He advised me on what to say and do, and assured me that he would take care of the matter. He drew up a statement for me to sign about the accident, which I did.
——
FF-2-89
Affidavit of Mattie Gibson
I am a retired cook. I have been a member of Peoples Temple since 1972. I have known Tim Stoen from that time until sometime in 1976. He was introduced to myself and others as the attorney for Peoples Temple.
To the best of my recollection, sometime in 1974 I asked Tim Stoen for his legal opinion regarding the sale of some property I owned in Fresno, California. He gave me his legal opinion and advised me about the sale of my property. This consultation took place in Los Angeles, California.
Frequently, over the years, I heard Tim Stoen speak as the attorney for the church and services and meetings at Peoples Temple churches, giving legal opinions and advice on church affairs, as well as the legal affairs of individual members.
—–
FF-2-191
Affidavit of Robert Wendall Gieg
[Handwritten notation: “Rough JC 9/3]
I am a poultry keeper. I joined Peoples Temple of the Disciples of Christ in May of 1969; around that time or somewhat later, I met Timothy O. Stoen (“Tim Stoen”) who introduced himself to me as the church lawyer.
In 1971, as a conscientious objection to the war in Vietnam, I was required to do “alternate service”. I was worried about my status because my employer did not employ me the required number of hrs which was specified to anyone doing “alternate service”. I sought and received Tim Stoen’s advice as to my legal rights under the circumstances, and what to do.
[Handwritten notation: “O.K. E.C. 9/5 OK HT 9/5”]
—–
FF-2-179A
Robert Wendell Gieg. May 1969, around that time I met TOS. I was referred to TOS by several members in the church. As a conscientious objector, I was required to do alternate service. I was worried about my status because my employer did not employ me the required hours of work. I sought TOS’s advice about my legal rights under the circumstances.
——
FF-2-214
AFFIDAVIT OF VERNON DEAN GOSNEY
I am a cook. I have been a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) since 1972, and have known Timothy O. Stoen (“Tim Stoen”) from that time until February 1977. Tim Stoen was introduced to me as the attorney for Peoples Temple.
In 1974, I receive legal advice from Tim Stoen about my status as a welfare recipient.
Again 1974 I received legal opinions and advice from Tim Stoen about a lawsuit I was considering against John Muir Hospital in California for malpractice
Frequently, over the years, I have heard Tim Stoen give legal opinions and advice on church affairs as the attorney for Peoples Temple. This was in public church services and meetings at the different Peoples Temple churches.
[Handwritten notation: “O.K. E.C. 9/4 OK HT”]
——
FF-2-147B
Rough 9/2 HT
Vernon Dean Gosney – cook
PT – 1972 – Knew TOS from that time. Was introduced to me as attorney for the church.
In 1974, I spoke with TOS in Redwood Valley about my status as a welfare recipient & he gave me legal advice concerning this matter.
In 1974 I asked TOS’s advice about suing John Muir hospital in California for medical malpractice. He discussed the merits of the case with me and advised me on how to proceed.
——
FF-2-213
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF JUANITA GREEN
I as a retired person. I have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1970. I have known Timothy O. Stoen (“Tim Stoen”) from that time until 1977. He introduced himself in church services as the attorney Peoples Temple.
In 1974 I received legal advice from him about property I had inherited from my parents. I gave him my deeds, and he agreed to handle the matter so as to insure my best legal advantage. I discussed the matter with him periodically over the next year.
Tim Stoen represented himself in Peoples Temple Church services and meetings as the attorney for the church many times over the years. I have heard him give legal opinions and advice on the church affairs in these meetings, speaking as the attorney for the church.
[Handwritten notation: “OK EC 9/5 OK HT”]
—–
FF-2-148A
Rough 9/2 HT
Juanita Greene – retired housewife
PT – since around 1970
Known TOS since that time. He was first introduced to me as attorney for PT.
Around 1974, one night in Redwood Valley – I sought his advice on a property matter. I had been offered a small sum of money to give up my interest in property my parents had left me in [illegible word] County. I asked TOS what to do about it and gave him my deeds and he said he would check the matter out. I discussed the matter with him several times thereafter, and he said he would take care of it, and see to it that I was not taking advantage of. He subsequently told me he had lost the deeds.
——
FF-2-128
Affidavit of Frankie Grigsby
I am a retired cook. I became a member of Peoples Temple of the Disciples of Christ sometime in 1969, and knew Timothy O. Stoen (Tim Stoen) from that time until he left for Guyana in February 1977. Tim Stoen had been introduced to myself as the attorney for Peoples Temple.
Sometime in 1974 I was injured on my job, at Trinity School in Ukiah. I consulted Tim Stoen for his legal opinion, and we talked on more than one occasion about the accident. He gave me legal advice on how to proceed so I could get some compensation for the injury. He eventually referred me to another lawyer, who took the case. Tim Stoen told me that he had talked about my case with this attorney, and when I was offered a settlement, Tim Stoen reviewed the offer, and gave his legal opinion that I should accept it.
Tim Stoen would often speak in church services at the different Peoples Temple churches as the attorney for the church. If a legal opinion was asked for about a church business he would give his legal opinion and advice. He also gave legal advice to many individual church members, both during and after church services.
——
FF-2-141
[Handwritten note: “Rough 9/2”]
Frankie Grigsby – retired cook
PT around 1969. I knew TOS from that time. TOS had been introduced to myself & others as attorney for PT.
Around 1974 I had an accident on my job at Trinity School in Ukiah. I asked TOS for his advice on what I should do. He talked with me on more than one occasion about the facts surrounding the accident and gave me legal advice about how to get some money to compensate me. He finally referred me to another lawyer (a Mr. Luther), who took the case and it was settled. TOS also told me that he could talk about my case with Mr. Luther and TOS advised me to accept the settlement that was offered.
——
FF-2-211
[Handwritten notation: “Rough 9/3 HT”]
AFFIDAVIT OF LEMUEL THOMAS GRUBBS II
By profession I am a school teacher. I became a member of plaintiff Peoples Temple of the Disciples of Christ, a Cal Corp (“The Church”) since February 1968. I have known Timothy O. Stoen (“Tim Stoen”) from sometime in 1969. I met him when he first began coming to the church in 1969. He very soon became the attorney for the church and introduced himself in church services as such.
In 1971 I met with Tim Stoen at his home in Redwood Valley and discussed the adoption of Kevin, Kelly and Clark Smith. He agreed to handle the adoption and drew up adoption papers which my wife and I signed at his direction. We spoke to him at a later date and he drew up a second set of adoption papers, as the first had been misplaced. [Deleted words: “He was given money for filing fees. However, Tim Stoen never completed the adoption.”]
In 1974 I received legal advice from Tim Stoen about getting a divorce. Tim Stoen gave me legal advice about the proceedings and the community property laws of the State of California. He drew up papers for the divorce proceeding which I signed in his presence and at his direction.
Tim Stoen over the years spoke as the church attorney, giving legal opinions and advice on church affairs on numerous occasions, in church services and meetings held at Peoples Temple churches.
[Handwritten notation: “OK. EC 8/4 OK HT”]
—–
FF-2-169A
Rough 9/3 HT
Lemuel Thomas Grubbs II – schoolteacher. PT February 17, 1968. Knew TOS since sometime in 1969. I met him when he first began coming to the church in 1969.
In 1971, I met with Tim Stoen at his home in Redwood Valley and discussed the adoption of Kevin, Kelly & Clark Smith. He agreed to handle the case and took money from us for filing fees. He drew up adoption papers which was signed at his direction. He did not pursue the matter because he lost the papers, so we again spoke with him about the matter and he drew up a second set of papers which I signed. A second filing fee was given to TOS. The adoption was
——
FF-2-169B
never completed.
In 1974 I discussed obtaining a divorce from my wife Sylvia Elaine Grubbs with TOS. He advised me as to my legal rights, the nature of the proceedings, and community property laws of the state of California. He drew papers for the divorce proceeding, which I signed.
——
FF-2-108
Affidavit of Patricia Lee Grunnet
My profession I am a primary school teacher. I have been a member of Peoples Temple of the Disciples of Christ since 1972. I have known Timothy O. Stoen since 1971. I was referred to him and to the church for help by Karl Irvin, President of the Disciples of Christ in Northern California which is the Denominal Regional Organization. I met Tim Stoen as the attorney for Peoples Temple and explained to him that my boyfriend was in prison and I was anxious to secure his release. After several consultations Tim Stoen wrote the Federal Parole Board on behalf of Peoples Temple, offering on behalf of the church to be held responsible for my boyfriend if they would see fit to parole him. [Handwritten additional sentence: “he did this on a number of occasions with respect to other prisoners over the years.”]
I frequently, almost weekly in fact, attended church business meetings from 1973 to 1976, where Tim Stoen gave organizational business advice as the church attorney.
——
FF-2-175B
Patricia Lee Grunnet
Member since 1972
Known TOS since 1971, referred to him & PT for help by Karl Irvin, President of the Disciples of Christ of Northern California, which is the denominational regional organization.
I met TOS as the attorney from Peoples Temple, explained to him my then-boyfriend was in prison, and I was anxious to secure his release. After several consultations TOS wrote the Federal Parole Board on behalf of the Church offering to be responsible for my boyfriend if they would see fit to parole him.
I frequently (almost weekly) attended church business meetings between 1973 and 1976, when TOS gave organizational business advice as the church attorney.
——
FF-2-13
Affidavit of John Harris
By profession I am a certified forensic pathologist I have been a member of peoples Temple of the Disciples of Christ (“Peoples Temple”, “the church”)”] since October 1969. I have known Timothy O.) “Tim Stoen”)”] from about that time until 1977. He was introduced to me as the attorney who handled church affairs. [Marginal note: “Does he have a license?”]
In Spring of 1970 I received legal advice from Tim Stoen regarding alimony and child support payments.
Sometime in 1971 I consulted Tim Stoen about a probation violation, and he again advised me as to what my legal rights were and what course of action I should pursue.
In 1972 Tim Stoen gave me legal advice regarding traffic violations. He dictated a letter for me to the judge and agreed to talk to him on my behalf.
In 1972 my probation was revoked and I went to jail. Tim Stoen gave me legal advice while I was in jail and arranged for bail. He also handled the payment of restitution, which resulted in my release form probation.
In 1973 Peoples Temple was interested in buying a printing firm in San Francisco called Infocom. I was working there at the time. Tim Stoen was negotiating on behalf pf Peoples Temple for the purchase of the business. I participated with him in meetings to discuss the purchase with the current owners. While I worked at that firm, I printed church literature. Tim Stoen reviewed all the material prior to printing for the legal implications of the content, and made corrections.
During 1973 Peoples Temple had a radio broadcast on KFAX. The station was planning on changing their format and cancelling our program. Tim Stoen was acting as the attorney for the church during that meeting.
In 1974 Tim Stoen gave me legal advice regarding a personal injury suit I was going to file against Penny’s. He discussed with me the merits of the case and referred me to another attorney. He later reviewed the settlement offer and advised me that it would be in my best legal interest to accept it, which I did.
In late 1974 I was involved in a car accident, and Tim Stoen gave me legal advice on this matter. Around 1975 I received legal advice from Tim Stoen on obtaining a passport. I was concerned because of my past police record. He also gave me legal advice on several occasions about welfare, social security and SSI. In 1976 Tim Stoen gave me legal advice regarding child support and the payment of alimony, and referred me to another lawyer.
He never made a charge to me for any of these services, which he extended to all church members without cost as part of the church program.
[handwritten insertion: “E.C. 9/4”]
—–
FF-2-177A – 177C
Rough HT 9/3
John Harris
Profession: forensic pathologist
PT Oct 1969. I have known TOS since about that time, when he joined the church.
He was introduced to me as the lawyer who was handling church business.
In Spring of 1970 I asked TOS for his legal advice regarding alimony and child support payments. TOS gave his legal opinion on the matter and agreed to help me resolve the matter to my best legal advantage.
Around 1971 I sought legal advice about a violation of probation for child support & alimony. Again he advised me as to what my legal rights were and what cause of action should be pursued.
I also consulted him for legal advice regarding traffic violations. TOS agreed to handle the matter and speak to the judge on my behalf. He dictated a letter for me to the judge in the Ukiah Courthouse. This was around 1972.
Again in 1972, TOS gave me legal advice regarding alleged probation violations. My probation was revoked & I went to jail. TOS gave me legal advice while I was in jail and arranged for bail. He handled the payment of restitution which released me from probation.
In 1973, PT was interested in buying a printing firm in San Francisco called Infocom. I was working there at that time. TOS was negotiating on behalf of PT for the purchase of the firm. I participated with him in meetings to discuss the purchase with the current owners, Mr. & Mrs. John Price. These meetings took place at 625 3rd St. When I worked at InfoCom I printed church literature, which TOS reviewed and corrected prior to printing for legality.
During 1973 PT had a radio broadcast on KFAX. The station was planning on changing their format and canceling our program. TOS, Harold Cordell & I spoke to Station Manager Judd Sterdevant. TOS was acting as attorney for PT during that meeting.
In 1974 TOS gave me legal advice regarding a personal injury suit I was going to file against Penney’s. TOS discussed with me the merits of the case & referred me to Jack Hanson of Ukiah. TOS later reviewed the settlement offer and legally advised that I accept it, which I did.
In late 1974 I was involved in a car accident. I received legal advice from TOS on this matter. He made a phone call on my behalf & recommended me to Dick Hodge.
Around 1975 I received legal advice from TOS regarding obtaining a passport. I was concerned because of my police record.
During 1975 I received legal advice from TOS on several occasions regarding a welfare, Social Security & SSI.
In 1976 I again received legal advice from TOS regarding child support & alimony payments. TOS discussed my case with me and referred me to another lawyer.
——
FF-2-24A – 24B
Affidavit of Linda Sharon Harris, a.k.a Sharon Amos:
By occupation I am a social worker and have been a member of Peoples Temple of the Disciples of Christ (“the church” “Peoples Temple”) since 1966. I have known Timothy O. Stoen (Tim Stoen”) since 1969when he became a member of the church. I have been a member of the Board of Directors of Peoples Temple for the last four or five years.
Part of Tim Stoen’s responsibility was to give legal advice to various members of Peoples Temple. He gave me advice over the years about a variety of legal matters including child support, an employment problem with the Mendocino County Welfare Department and represented me in the adult adoption proceeding. He also advised me with respect to the legal problems of a number of church members that I was assisting in social work areas.
Later, in 1975, when most of us, including Tim Stoen had moved to San Francisco from the Mendocino County area, he accompanied me and several other church members to a grammar school in the San Francisco Unified School District where he met with school officials to discuss the problems of several children whose parents were church members. He there introduced himself as the attorney for Peoples Temple. I also attended numerous public and private social affairs with him. In 1975 and 1976 where he introduced himself as the attorney for Peoples Temple.
At one time in 1975 we were planning to start our own private school for certain children of Peoples Temple parents who were experiencing trouble learning in the public school system. Tim gave us legal advice on how to establish a private school. He was particularly knowledgeable in this area because he had represented all of the school districts in Mendocino County while working there.
During 1975 we had developed a sort of team approach to counseling, especially of the poor due to the cross-disciplinary nature of their problems. A team of three including an attorney or paralegal, a social worker and a secretary would interview. I often worked on a team with Tim in 1975 and 1976, as he was very much involved in the program. We interviewed and advised hundreds of persons, many of whom were members of the church.
In 1973 when the Church Board first conceived of the idea of establishing an Overseas Mission, Tim reviewed the laws of a number of nations and advised the Board concerning the legal and political affairs of the nations reviewed, including Guyana.
He participated in the selection of Guyana as the site by coming to the country as part of a team which included myself and doing a legal evaluation of its laws and regulations and their probable effect on the mission development. He recommended a legal structure for the formation of the Mission organization. After Guyana had been selected as the mission site, he prepared a variety of legal forms including powers of attorney, consents, authorizations and releases all of which were used in the arranging nor assisting persons to come to Guyana. He also assisted in obtaining passports, and gave legal advice and wrote up affidavits which were used to obtain passports. He counseled persons concerning dealings with creditors, sale and distribution of assets, tax and other matters germaine to winding up their affairs in the U.S.A. In my case I had a problem in obtaining my passport and he gave me legal advice and wrote up some affidavits that were given to the Passport Department which assisted in obtaining my passport.
[handwritten insertion: O.K EC. 9/5 OK HT 9/5]
—–
FF-2-144A
Linda Sharon Harris, aka Sharon Amos
Rough 9/2 Gene
By occupation I am a social worker, and have been a member of PT since 1966. I have known TOS since 1966 when he became a member of PT.
TOS would give legal advice to members regarding personal legal matters. He gave me advice over the years about a variety of legal matters including child support and my employment at the Mendocino County welfare department with respect to an employment protest, and also with respect to the legal affairs of a number of members of the church who I was assisting in social work areas.
Later, in 1975, when most of us, including TOS (who was then employed by the San Francisco DA) moved to San Francisco, he accompanied me and several others to a grammar school in the San Francisco Unified School District, where he met with school officials, introducing himself as attorney for Peoples Temple and San Francisco Deputy District Attorney. We discussed problems of the children of certain members of PT. I also attended numerous social affairs, public and private with TOS in San Francisco during 1975 & 1976, when he introduced himself as the attorney for Peoples Temple.
At one time in 1975 when we planned to start our own school in San Francisco for children of members and others, he gave us legal advice on how to establish a private school.
——
FF-2-144B
I was also present when TOS gave legal advice to many PT members over the years because we had developed a sort of total counseling format where a secretary, social worker, and attorney would counsel together. TOS was very much involved in the program.
In 1973 when the Church Board first considered the idea of establishing an overseas mission, TOS reviewed the laws of a number of nations, including Guyana, and advised the Board concerning the legal and political affairs of the nations reviewed.
After Guyana had been selected, he prepared a variety of legal forms including powers of attorney, consents, authorizations and releases, which were used in the administrative function of preparing persons to move to Guyana. He also assisted in obtaining passports, including drawing affidavits of birth and other documents. He counseled persons concerning dealings with creditors, sale and distribution of assets, and other matters germane to winding up their affairs in USA. In particular, I had a problem obtaining my passport, and in _____(date) he gave me legal advice and wrote up some affidavits that were given to the Passport Department which assisted in my obtaining my passport.
In [blank space] he also arranged can handle an adult adoptive proceeding for me to assist in the care of my children.
——
FF-2-179E
Osialee Hilton, housewife, February 1970, 1973, TOS was introduced to me as the attorney for PT. In 1973, he gave me legal advice concerning a civil suit I was involved in.
——
FF-2-205
AFFIDAVIT OF DORIS HOWARD
[Handwritten notation: “Rough 9/2 H.T.”]
I am a retired person. I have been a member of Peoples Temple of the Disciples of Christ (“Peoples Temple” & “the church”) since 1971, and I have known Timothy O. Stoen (“Tim Stoen”) from that time until 1977.
Sometime in 1973 I met with Tim Stoen, and he gave me legal advice about my son, John Haines. He gave me advice about how to handle my son’s case so that it would be to his best legal advantage. From time to time I consulted with Tim Stoen about the progress of my son’s case and he gave his legal opinion and advice each time.
Throughout the time I have been a member of Peoples Temple, until 1977, when he left for Guyana, Tim Stoen would be called upon in services and meetings at the Peoples Temple churches to give legal advice and opinions concerning church affairs. I have heard him give such legal advice and opinions, speaking as the attorney for Peoples Temple. He also gave legal advice concerning the legal affairs of individual church members, always without charge, as a part of the church legal services program.
[handwritten notation: “O.K. E.C. 9/4”]
—–
FF-2-154
1. Doris Howard (retired)
PT – since 1971 – Known TOS since that time.
2. Around 1973, I asked & received advice from TOS about my son John Haines. He was in jail at the time and TOS gave me legal advice on what to say in court & how to handle John’s case, so that it would be to his best legal advantage. I spoke with TOS on several occasions about the matter.
——
FF-2-182
Affidavit of Barbara Hoyer: (1 of 1)
I am a social worker, I joined Peoples Temple of the Disciples of Christ (“the church”) in 1971 and have known Timothy O. Stoen: (“Tim”) since that time. For several months in San Francisco in San Francisco we worked closely together. I was employed by the Mendocino County Welfare Department in the fall of 1972 and worked there till April of 1976. During most of that time Tim was the Assistant District Attorney for Mendocino County and was charged with the specific function of advising and representing the Welfare Department. We also advised various church members on welfare problems and I would quite often confer with Tim about them and he would advise me on how best to help them.
Later, around June of 1976 I moved to San Francisco. There, till I found a job, I worked for Tim as a volunteer voter fraud investigator. He was then with the San Francisco District Attorney Office. I was asked to help him by the church because he was so busy that he could not find sufficient time to do the church legal work and the idea was that I would free him up so he would have some more time to do church legal work. During the time I worked with Tim I went to his office several times and saw him working on church matters and heard him discussing church matters on the telephone.
[Handwritten notation: “OK. E.C. 9/6”]
—–
FF-2-164
Rough 9/2 EC
Hoyer, Barbara
Prof: social worker. Joined PT fall of 71. Knew TOS from then. I was employed by the Mendocino County Welfare Department in fall of 1972, and worked there until 4/76. At that time TOS was Assistant District Attorney for Mendocino County and was charged with the specific function of advising and representing the Welfare Department.
[paragraph marked “Out”!] For the last 1 1/2 years of my employment I was the Medical Worker for Mendocino County Hospital. Among others, I took all of the applications for members of the Unification Church residing in their facility at Booneville, California, “Ideal City Ranch.” At TOS request I provided him with copies of all intake sheets for such persons.
Later about June 4, 1976, I moved to San Francisco. There till I found a job, I worked as a volunteer voter fraud investigator for TOS who was then employed by the San Francisco DA. I was asked to help him by the Church in order to lighten his workload so he would have more time to do Church legal work. During the time I worked for TOS I went to his office several times and saw working on Church matters and heard him discussing church matters on the telephone.
—-
FF-2-201
AFFIDAVIT OF ALICE INGRAM
[Handwritten Notation: “Rough 9/2 HT”]
By profession I am a caretaker of retarded children. I have been a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) since 1969. I have known Timothy O. Stoen (“Tim Stoen”) from about that time until early 1977 when he went to Guyana. He introduced himself to me as the attorney for Peoples Temple.
In 1974 I received legal advice from Tim Stoen regarding a second loan on my house on Road E in Redwood Valley, California.
In 1973 I participated in a demonstration and picket line at the Examiner building in San Francisco organized by Peoples Temple. Tim Stoen was present and gave legal advice to myself and others as to how to conduct ourselves on the picket line, so as not to get into any legal difficulty. He also spoke to police, reporters, and others as the attorney for Peoples Temple.
[Handwritten notation: “OK E.C. 9/5 OK HT”]
—–
FF-2-184
AFFIDAVIT OF MARION LEE INGRAM
[Handwritten notation: “Rough 9/3 HT”]
I am a graduate of the State College of New York. I am currently working as a primary school administrator and art teacher. I have been a member of plaintiff Peoples Temple of the Disciples of Christ (“the church”) since 1969, and have known Timothy O. Stoen (“Tim Stoen”) from that time until the early part of 1977. I first became aware of his being the attorney for the church when I heard him say that he was at a church meeting in Redwood Valley. He later introduced himself to me as the attorney for Peoples Temple.
I began employment with Pacific Gas & Electric in Ukiah, California in 1970. Periodically, over the following four years I received legal advice from Tim Stoen regarding my job. He advised me of my legal rights regarding the retention of my job and advised me on how to proceed in registering complaints with the ACLU and other organizations about discrimination I had experienced on the job. On one occasion he dictated a letter that I signed, directed to the management of Pacific Gas and Electric.
Throughout the years I have heard Tim Stoen speak as the attorney for the church in giving legal advice and opinions on church affairs in church services and meetings. He gave legal advice to numerous members of the church as part of the ongoing church programs.
[Handwritten notation: “OK EC 8/4 OK HT”]
—–
FF-2-170
Marion Lee Ingram
Rough 9/3
PT 1969 – Knew TOS since about that time
He publicly represented himself in church services as attorney for PT.
I began employment with PG&E in Ukiah in 1970. Periodically, over the next four years I received legal advice from TOS regarding my job. He advised me of my legal rights regarding the retention of my job and advise me on how to proceed in registering complaints with the ACLU & other organizations about discrimination I’d experience at PG&E. On one occasion he dictated a letter that I signed, directed to the management of PG&E.
——
FF-2-203
AFFIDAVIT OF BEATRICE JACKSON
[Handwritten notation: “Rough 9/2 HT”]
I am a retired person. I became a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) in about 1971, and I have known Timothy O. Stoen (“Tim Stoen”) from that time, until Feb 1977. I was referred to him by a church member, and he introduced himself to me as the attorney for Peoples Temple.
In 1973, after a church service in Los Angeles, Calif. I met with him about property I owned in Abilene, Texas. I asked him for his legal opinion regarding the sale of that property, and he gave me legal advice regarding the sale.
Throughout the time I have been a member of Peoples Temple, I have heard Tim Stoen publicly, in Peoples Temple services, speak as the attorney for the church, giving legal advice and opinions about church affairs. He would also give such advice to individual members. He was often referred to in church services as the attorney for the church, while he was present.
[Handwritten notation: “OK E.C. 9/5 OK HT”]
—–
FF-2-139B
Beatrice Jackson – retired person
[Handwritten note: “Rough 9/2”]
PT around 1971. Knew TOS since that time. I was referred to him and he introduced himself to me as the attorney for PT.
About 1973 after a church service in Los Angeles, California, I met with him about property I owned in Abilene, Texas. I asked him for his legal opinion regarding the sale of that property and he gave me legal advice regarding how to handle the sale.
——
FF-2-208
Affidavit of Donald Jackson
By profession, I am a school teacher. I have been a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) since 1968. I met Timothy O. Stoen (“Tim Stoen”) soon after he joined in 1970. He frequently gave legal advice to Peoples Temple members and he had given me his card instructing me to call him at his office in the Ukiah County Courthouse.
In approximately April of 1974, I consulted Tim Stoen about an automobile accident I was involved in; he took care of it expeditiously and no court appearance was required.
Then, in August of 1974, I was involved in another accident that caused severe damage to my legs. He advised me concerning a civil suit which I initiated on this occasion.
In October, 1974, I became eligible for disability benefits which Tim Stoen advised me to apply for.
[Handwritten notation: “OK E.C. 9/4”]
—–
FF-2-229
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF KATHRYN JACKSON, nee KATHRYN GRAUMANN
BY profession I am a medical laboratory assistant. I have been a member of Peoples Temple of the Disciples of Christ (“the church” “Peoples Temple”) since 1969. Timothy O. Stoen (“Tim Stoen”) became a member of the church soon after, and I have known him from that time until early 1977. He quickly assumed a prominent role in church affairs, became a member of the Board and took on the function of attorney for the church.
During the years 1971 and 1972 I did research for Tim Stoen at his request. He had me research the newspaper columns of one Lester Kinsolving. He explained to me that he wanted all the background on Mr. Kinsolving that I could find so that he could give the church Board a legal opinion on what course of conduct to follow with regard to Mr. Kinsolving.
Frequently, over the years, I have heard Tim Stoen give legal advice and opinions, speaking as attorney for Peoples Temple, on church affairs in public church services and meetings at the various branches of Peoples Temple. He also gave legal advice and opinions to many, many church members over the years, as a part of his function as attorney for the church.
[Handwritten notation: “OK. 9/5 E.C. HT 9/5”]
——
FF-2-190
Affidavit of Lourece Jackson
I am a cook. I joined Peoples Temple of the Disciples of Christ (“The Church”, “Peoples Temple”) in 1973; when I joined I knew that Timothy O. Stoen (“Tim Stoen”) was the lawyer for the church because it was frequently announced in the meetings.
During 1976 and 1977 In order to solicit money for donations for the church in the city of San Francisco, I had to obtain a Solicitor’s License issued by The Church which Tim Stoen had signed as legal counsel for Peoples Temple.
[Handwritten notation: “OK EC 9/5 OK HT”]
—–
FF-2-179A
Lourece Jackson, 1973, 1973. I know that TOS was a lawyer of the Temple. In order to solicit donations for our church I had a Solicitors License which TOS had signed as legal counsel for PT.
——
FF-2-199
Affidavit of Paulette Jackson
[Handwritten notation: “Rough 9/3 JC”]
By profession, I am a medical receptionist. I joined Peoples Temple of the Disciples of Christ (“the Temple”) in November 1971, and in December of the same year was introduced to Timothy O. Stoen as the lawyer for the Temple.
In 1974, he advised me in the matter of the guardianship of Julie Runnels. He advised me how to testify in court. [deleted words: “that I had known the child and her mother and her mother five years although I had actually known her only two years.”]
In 1974, he also advised me how I could get benefits from the county [deleted words: “before I was actually entitled to them”] as Julie’s guardian.
[Handwritten notation: “OK 9/5 E.C. OK HT”]
—–
FF-2-179F
Paulette Jackson, receptionist, November 1971, December 1971. He introduced himself as a lawyer for PT.
In 1974, he gave me legal advice concerning the guardianship of Julie Runnels. He advised me to testify in court that I had known the child & her mother 6 years although I had actually known her only 2 years.
In 1974 he also told me how to get benefits from the County before I was actually entitled to them as Julie’s guardian.
——
FF-2-179G
Thelma Jackson, medical assistant, 1968, 1970. It was stated that he was an attorney & could be consulted for legal advice.
In 1974, by husband Don & I consulted TOS for legal advice concerning a civil suit Don was bringing for personal injuries to his leg.
——
FF-2-167
Rough 9/2 EC
Ronald DeVell [Deval] James
Profession: Student – member since 1972. Known Stoen since 1972, introduced as the church attorney.
Consulted Summer of 1975 about incident where he and a friend were mobbed in Santa Rosa, California and I was to appear as a witness in a criminal trial. The incident was of great concern to the church because it had racial overtones and occurred during the trip on a church-owned and operated bus. The church took this attack as an act of hostility against the church as such and took much pains in assisting the prosecution of the case in attempt to prevent further outbreaks of overt, violent racism. TOS spent several hours preparing us to testify in the case.
——
FF-2-196
[Handwritten notation: “Rough 9/3 HT”]
AFFIDAVIT OF CLARA JOHNSON
By profession I am a certified teacher. I have been a member of plaintiff Peoples Temple of the Disciples of Christ (“church” “the church”) since 1972 and have known Timothy O. Stoen (“Tim Stoen”) from that time until 1977. Tim Stoen introduced himself to me as the attorney for Peoples Temple.
Sometime in 1976 I received legal advice from Tim Stoen about the acceptance of a settlement offer I had received, arising out of a car accident that my daughters had been involved in. Tim Stoen gave me his legal opinion, based on our discussion of the merits of the case, that I should accept the offer, which I did.
I often heard Tim Stoen speak in church services at Peoples Temple churches as the attorney for the church, giving legal advice and opinions on church affairs. He gave advice to many, many members on their legal affairs, often after church services as part of his function as attorney for the church.
[Handwritten notation: “OK EC 8/4 OK HT”]
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FF-2-170
Rough 9/3 EC
Clara Johnson – certified teacher
PT 1972 – Knew TOS since that time.
TOS introduced himself to me as the church attorney.
Sometime in 1976 I spoke with TOS about a settlement offer I received on behalf of my daughters Janice & Joann Johnson, from a car accident they had being involved in. TOS discussed the merits of the case with me and advised me to accept the offer, which I did.
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FF-2-179A
Earl Johnson, 1972, 1972. I was told he was the lead attorney for the Temple.
In 1972 I had a conversation with TOS about some property [illegible word]
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FF-2-204
Affidavit of Patsy Johnson
I am a dancer. I have been a member of Peoples Temple of the Disciples of Christ since spring of 1972. I was aware of the fact that Timothy O. Stoen (“Tim Stoen”) was the attorney for the Temple in 1975 when he announced that we could see him for legal advice as a part of the “Peoples Temple Free Legal Services” program.
In 1975, I consulted Tim Stoen for legal advice. I was involved in an automobile accident and I was required to pay a fine or go to jail. I showed Tim Stoen the ticket I received. He advised me on how to proceed with the matter so that I wouldn’t have to go to jail.
In 1975, he advised my mother on an insurance matter in my presence.
[Handwritten notation: “O.K. E.C. 9/4”]
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FF-2-179E
[Paragraph crossed out] Robert Johnson, retired longshoreman, 1969, 1971. I was told that TOS was attorney for the PT & I consulted him for legal advice. In 197?, he advised me concerning my legal rights in a public demonstration.
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FF-2-10A
Affidavit of Laura Johnston: (1 of 2)
I am a social worker by profession. I first joined Peoples Temple of the Disciples of Christ, (“the church,” “Peoples Temple”] in February of 1970, just a few months after Timothy O. Stoen (Timothy Stoen or “Tim”). I knew Tim Stoen till he left Georgetown, Guyana in June of 1977. I stayed at his home in Redwood Valley from February to June in 1970. During that time I constantly heard him involved in church legal business.
I was employed by the Mendocino County Welfare Department as a social worker in August of 1970 and worked there till March of 1977. During most of that time Tim was employed as Assistant District Attorney of the Mendocino County District Attorney. He was the Attorney that advised the Welfare Department. During those years I would ask his advice on how to assist Peoples Temple members in resolving problems or potential problems that they had with welfare.
During my career in Mendocino County the church owned several care homes in Mendocino County which were county licensed. Several other county licensed homes were owned and operated by church members. The licensing agency was the Welfare department. One of my, and Tim’s duties for the church was to advise and counsel on welfare matters including care home licensing matters. During the time we worked together in Mendocino County, at least once weekly or more often, Tim Stoen advised church officials and care home operators concerning legal aspects of the operation of care homes. Of course, all such advice and help was without charge. These seniors were extended as a part of the “people helping people” philosophy”]
I would regularly for years counsel people at church on their welfare problems and Tim would regularly counsel with me giving legal advice on the same subject. He also advised me on many occasions to select members of church volunteers to come to various court proceedings in sympathy with the causes of church members. On such occasions he would tell me the background of such cases, how to act and what to say.
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FF-2-10B
Affidavit of Laura Johnston Kohl: (2 of 2)
When Tim Stoen was in Guyana in the Spring of 1977, I was also there and I recall that he gave legal advice to many members there and also to church officials about the conduct of their affairs both in Guyana and the United States. He also did the legal work on buying a house in Georgetown and investing church funds in Guyana including the purchase of Government Bonds.
[handwritten insertion: “Ok E.C 8/4”]
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FF-2-136A – 136B
[Handwritten “rough” notes made by Eugene Chaikin for affidavit by Laura Johnston]
Profession: social worker. First joined Peoples Temple February 1970. TOS [Timothy O. Stoen] had joined a few months prior. Know him till he left Georgetown in May or June of 1977. I stated his house in Redwood Valley from February to June 1970. During that time I constantly heard him involved in church legal business.
I was employed by the Mendocino County Welfare Department as a social worker in August of 1970 and worked there until March 1977. During most of that time TOS was employed as Assistant District Attorney by the Mendocino County District Attorney. He was the attorney that advised the Welfare Department.
During those times I would often ask his advice on how to assist Temple members in resolving problems or potential problems that they had with the welfare departments, including Mendocino County.
In May of 1970 he advised me on obtaining a divorce in San Francisco County. I would regularly [illegible word] counsel people at church on their welfare problems, and TOS would regularly counsel with me giving legal advice to welfare recipients in Los Angeles County, San Francisco County and Mendocino County.
He also advised me on many occasions to select numbers of church volunteers to come to various court proceedings in sympathy with the causes of church members. On such occasions he would tell me the background of such cases, how to act and what to say.
When TOS was in Guyana in the spring of 1977, I recall that he gave legal advice to many members there and also to church officials about the conduct of their affairs both in USA and Guyana, including buying a house in Georgetown, investing funds in Guyana including the purchase of government bonds.
During my job & career in Mendocino County, Peoples Temple owned care homes which were county licensed. Several other care homes were owned and operated by members & licensed by Mendocino County. The licensing agency was the Welfare Department. One of my duties for the church was to counsel and advise on welfare matters, including care home licensing matters. During the time we work together in Mendocino County, at least on a weekly basis or more frequently, TOS advised church officials and care home operators concerning all legal aspects of the operation of care homes and obtaining and keeping residents or patients.
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FF-2-130
Affidavit of Brenda Jones
By profession I am unit assistant for hospital in central supply. I have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1972, and I have known Timothy O. Stoen (Tim Stoen) from that time until 1977. I was introduced to him as the attorney for the church.
In 1975 I received legal advice from Tim Stoen on my status as a welfare recipient. I spoke with him about the matter subsequently and he gave me further legal advice.
I have often heard Tim Stoen speak as the attorney for Peoples Temple at meetings and services in the various churches, giving legal advice and opinions on church affairs. Whenever a legal opinion was called for, Tim Stoen would give that opinion.
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FF-2-216
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF ELIZA JONES
I am a retired person. I first joined Peoples Temple of the Disciples of Christ (“Peoples Temple”) in about 1970, and I have known Timothy O. Stoen (“Tim Stoen”) from that time until early in 1977.
I was involved in a car accident in 1975 in Redwood Valley, California. I spoke with Tim Stoen about the accident and he gave me legal advice about my liability and what I should do.
Over the years I have heard Tim Stoen speak as the attorney for the Peoples Temple on many occasions during church services, when he would be asked for his legal opinion on different church matters. He also gave legal advice and opinions to individual members during and after church services at the different Peoples Temple churches.
[Handwritten notation: “O.K. E.C. 9/4 OK HT”]
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FF-2-147A
Rough 9/2 HT
1. Eliza Jones – retired person
PT – @ 1970 – TOS same time
2. I had a car accident in 1975 in Redwood Valley, California. I spoke with TOS about the accident and he gave me legal advice about my liability and how to proceed.
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FF-2-17A
Affidavit of James W. Jones:
I have been the pastor of Peoples Temple of the Disciples of Christ, and its predecessor organizations, since 1949 (“the church”, “Peoples Temple”). I am, and for some years have been a Minister ordained by the Christian Churches (Disciples of Christ), of which denomination the Peoples Temple is an affiliated church. I have been an activist, striving to make the Christian goals of equality and brotherhood social reality through the demonstration of people caring for each other. I thus developed a large interracial church with extensive human service programs.
When Timothy O. Stoen (Tim Stoen ) joined my church in 1969 I was thrilled. Besides the addition of another sincere, committed member I was overjoyed to have his help because in my rapidly growing church I needed a concerned, dedicated lawyer badly. I also needed an activist associate minister badly and Tim rapidly began to fill both roles. I trusted him fully and entrusted him with more responsibility than any other single member of the organization. I was very greatly saddened by his departure in 1977.
I have read the affidavits of Jack beam, Eugene Chaikin, Joyce Parks, Maria Katsaris, Kay Nelson, Tish Leroy, Harold Cordell, Carolyn Layton Prokes, Carol Stahl, Terri Buford and Mike Prokes [Handwritten addition: “and Harriet Tropp”]. To the extent that I have personal knowledge of the things therein described they are true and correct. I did consult privately with Tim Stoen about the Medlock gift, and Maria Katsaris problems with her father. I did consult with Tim Stoen about problems with Jim Cobb. In fact I consulted with him privately in addition to publicly about most of the problems of the church which had any kind of legal implication. I am sure that over the years he, through his legal knowledge and activities, gained more confidential information about Peoples Temple and its members than any other living person.
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FF-2-17B
He was my chief legal advisor and I did nothing either with respect to the church or with respect to my own personal legal affairs without first consulting him and getting his legal approval. From sometime in 1969 through summer of 1972, and again from January of 1973 through the summer of 1975 he was my, and the churches only legal adviser. Everything that was done in connection with Maria Katsaris, James Cobb and Mabel and Wade Medlock, was done with his informed advice & consent.
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FF-2-7A – 7B
[Editor’s note: This is a rough draft, handwritten by Eugene Chaikin, of the affidavit of Johnny Moss Jones which appears below.]
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FF-2-12A
Affidavit of Johnny Moss Jones
While in the U.S.A I was employed as a public programs administrator. I have been a member of the Peoples Temple of the Disciples of Christ (“the church”, “Pepples Temple”) since 1970, and became and remained an Associate Minister since 1972. I have known Timothy O. Stoen (“Tim Stoen”) since 1970.
He advised me on, among other things, a Guardianship proceeding, traffic matters, various legal problems of members, and on church organizational matters. In May of 1976 Peoples Temple held a mass meeting in the Los Angeles convention center jointly with Nation of Islam. Approximately 20,000 persons attended from across the country. Tim Stoen was the speaker who introduced Rev. Jones. Tim was introduced as Deputy District Attorney for San Francisco County, Attorney for the Chairman of the Board of Peoples Temple. Joseph Freitas, the District Attorney of San Francisco County was present on stage and also introduced. Next to Rev. Jones himself, for years Tim Stoen was the most prominent member of the church. He very frequently appeared in public as a spokesperson for the church and his “weight” as an attorney and as a District Attorney lent strength to his appearances.
Tim Stoen first went to Guyana in the winter of 1973 with a Peoples Temple group, including myself. He was there for two weeks. He was the only legal adviser for the group in analyzing Guyana laws and regulations, forms of organization, trade and ownership regulations, and all of the other laws pertinent to setting up a mission.
Tim went to Guyana again in February of 1977 and stayed there till May or June of that year, except for a brief trip alone to Europe and a trip with a Peoples Temple group including myself to the island of Grenada in the Caribbean where the group studied the possibility of establishing a second mission there and Tim provided legal advice, including participation in discussions with the Prime Minister. While in Guyana he studied to prepare for an examination for the Guyana Bar, and had made application for an Instructorship at the University of Guyana. He did considerable legal work including a review of the agricultural lease and
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FF-2-12B
corporation, advised on the purchase of house (that was purchased) and on the purchase of several other investments and other items of real property (that were not purchased), negotiated the settlement of a dispute over the purchase of lumber, advised numerous church members about legal matters in the United States, and did sundry other legal work. During this period of time I was also in Guyana and often worked with Tim on these matters.
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FF-2-141
[following entry x-ed out]
Sandra Jones – laboratory assistant
PT since 1956. I have known TOS since about 1969. Soon after his joining the church he announced in a church service in Redwood Valley that he was acting as attorney for Peoples Temple and anyone who had a legal problem could discuss it with him after service. He made the same announcement numerous times in San Francisco, Redwood Valley & Los Angeles.
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FF-2-6A
[Editor’s note: This rough draft, handwritten by Eugene Chaikin, of an affidavit of Maria Katsaris is illegible.]
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FF-2-160A
Tim Stoen by Penny [deleted name: “Silver”] Kerns
1. Tim gave my son Phil legal advice on numerous occasions. He helped get him out of C.Y.A. [California Youth Authority] in 1968 and then when Phil escaped from C.Y.A. a couple of years later, Tim knew where he was and kept in touch with him although Phil was a fugitive. He even had Phil call him collect on several occasions – however, Tim didn’t tell me where Phil was hidden at, though Tim knew. He didn’t report Phil’s whereabouts to the authorities.
2. When I had the “Penny Kerns Show” in Ukiah, California, I taped numerous people throughout town on a talk show basis, when Peoples Temple was under attack by the press. I did this legally and openly. One of the people that I interviewed was a member of the Sheriff’s Department. When Sheriff Bartlemeau [Bartholemew] heard about it, he got angry and threatened me with arrest. Tim advised me to make a copy of the tape and to then return the tape to the T.V. station. (Tim was D.A. at this time). I took the tape to Edith Bogue and Harold Cordell and they put the contents of the tape on another tape and I returned the tape to the T.V. manager, who then fired me.
Also, when Tim was D.A. in Ukiah, he left his job to appear on my T.V. show. He knew that I was a member of Peoples Temple. Sometimes I would call him at work and he told me to be careful because everyone there were “fascist bastards”.
3. When I won an insurance case against the Los Angeles Herald Examiner due to an auto accident during working hours, I was awarded over $10,000 from them and also from State Farm. Because of this accident I was forced to go on welfare and had thousands of dollars worth of medical bills. When I asked Tim Stoen if I had to notify the Welfare Department about this money, he told me no – that I didn’t have to tell anyone about money awarded in an accident case. I also asked him if I had to tell the IRS and he said that I didn’t have to pay tax on it either. I later was told by a Social Worker friend that I was supposed to have notified the Welfare Department and I had committed a felony.
4. When I worked for a doctor in Los Angeles, I learned that this doctor was involved in Welfare Fraud and Insurance Fraud. I went to Tim about this and wanted to turn this doctor in. Tim told me to Xerox all his records, which I did. I Xeroxed every record that the doctor had. I was especially upset because he had filed a false claim on my behalf and was afraid that I would get into trouble since I worked for him. Anyway, Tim told me to not report him and had me turn in the records to him, and I don’t know what he did with them. He told me that we might need the doctor later for something.
5. In Los Angeles, David Wise wanted me to kill my children who had left the church. This conversation took place on a Sunday, and it greatly upset me. Later that night, I learned that Tim Stoen was in the church counseling office working on legal matters. I found David Wise crazy out of his mind on drugs and threatening suicide and I went to Tim and asked him to come and help me. He refused to come to help and came only upon my insistence. He said he had a lot of legal work to do.
6. When my son was in jail in Santa Rosa for car theft, Tim led me to believe that he paid for my son’s attorney and even said that he would sell one of his expensive couches in order to help pay for Phil’s defense. He also had me give the attorney who defended Phil his phone number so that he could talk to him. Also, when my son went AWOL from the Army, Tim talked with him and advised him legally. And, while my son was stationed at the L.A. missile base, I told Tim that Phil had showed me classified federal material that he had slipped off the base and that Phil had plans to climb the fence and get out if there was a major missile alert – Tim told me to tell Phil
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FF-2-160B
to be careful. I was very upset over Phil’s taking this classified information off the base, which showed pictures and instructions of how missiles are made. Also, my son took me up to the base one night in the middle of the night and showed me how the base was laid out. He told me how the guards were on drugs and played Russian Roulette for the fun of it. (Later 17 of these guards were busted on drugs.)
7. When Tim Stoen was Assistant D.A., I told him that the Redwood Valley Baptist Preacher Dan Duree, with whom I had worked at the T.V. station, said that Dean DeVries, in charge of the Ukiah Daily Journal, had told him that Peoples Temple would bomb the San Francisco Herald Examiner. He said that he was glad to have the information that maybe we could use it later. He did nothing about this.
8. Tim Stoen was involved somehow in the situation of the court reporter who had his daughter blow her brains out but I don’t remember the details of this.
9. Tim Stoen had me call ministers all over Ukiah and tape them on the telephone and inquire about their beliefs. He didn’t tell me this was illegal and told me that I did a good job. I called almost every minister in town. I don’t remember the details of this so it probably isn’t a good example.
10. When Tim Stoen was Assistant D.A. he knew that I found Leo Wade having sex with the preacher Ross Case in my home. I wanted to report this to the police but Tim encouraged me not to. But, he had me go to the principal of the school where Ross Case taught because Tim said that the principal should know what kind of person was teaching children and so I did this. Karen Layton was one of the people who went with me and I don’t remember the other person. Tim told me to tell the principal in detail what I had seen Ross Case doing sexually with Leo Wade, and I did this. I later learned that this should have been handled legally or in some other way. I never understood why Tim would have me do something like this, when he was an attorney.
11. When Tim Stoen was D.A., I told him that John Biddulph, who was a narcotics offender, carried an automatic weapon in the glove compartment of his pickup truck, but Tim ignored me. Also, I told Tim that one night John Biddulph told me that two men had come to his mother’s home and threatened to kill Jim Jones, but, when I reported this to Tim, he did nothing about this either. I never understood this.
12. Tim Stoen made up the statements and had the parents sign the statements and all people spanked publicly. This included the Myrtle children’s spankings and all adult spankings. I even got spanked and he approved of all of this.
13. Concerning John Biddulph. Shortly after I had told Tim about John carrying a gun, John defrauded the furniture store where he worked of all kinds of money and split the area. It seemed to me that if Tim had listened to me in the first place, being the D.A., that this could have been prevented.
14. When I told Tim Stoen that I knew of some drug pushers and asked him what to do about them, he told me to warn them that the police were after them. This was the first year I came to Peoples Temple. Also, this same period of time, he had taken in a hitchhiker who was AWOL from the Army (but I didn’t know it). I let him stay in my home for several days and then he went on. Later the C.I.A. came to ask about him and Tim Stoen told me lies to tell the C.I.A. about him. He wanted to help the young man get out of the service and he told me to tell the C.I.A. that the young man was homosexual and a child molester – I don’t remember the rest that Tim had me tell the agent. Tim told me that C.I.A. agents were sick people and to not worry that I was doing the right thing as he was worried the young man would crack on his job (he was stationed in a missile base in Alaska or someplace up north) and could cause a nuclear war.
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FF-2-125A – 125B
Undated scrap of paper from Ellen Klingman
Contact Mike Kingman because he [Tim Stoen] gave him legal advice how to avoid the draft. Mike was down to 55 days before being called in the service and I think Tim wrote a letter to. the government concerning Mike’s case.
Ellen [Klingman]
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FF-2-158
Demosthenes Kutulas
By profession I am a maintenance supervisor. I have been a member of PT since 1966 and have known TOS from 1969 when he joined the church, till early in 1977.
Over the years TOS gave me legal assistance in several matters. He prepared the legal papers for me to obtain guardianship of Tommy Beikman in 1969 or 1970. He assisted and gave me advice on how to deal with the Mendocino County Planning Commission with respect to obtaining a permit for certain fuel tanks I had placed on my property in Mendocino County. He also helped me cash certain trust fund certificates.
I also discussed church legal business with him from time to time. I went to his office at Mendocino County District Attorney from time to time for such discussions.
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FF-2-107
Affidavit of Georgia Lacy
I am a housewife. I have been a member of Peoples Temple of the Disciples of Christ since 1969. I have known Timothy O. Stoen (“Tim Stoen”) since he joined Peoples Temple in 1969. I was referred to him by a member of the church as the attorney for Peoples Temple.
In 1972 and 1973 Tim Stoen gave me legal advice about a real property matter. He gave me legal advice in 1974 about the guardianship of children. In 1975 and 1976 he again gave me legal advice about domestic relations problems with my husband, George Lacy. In 1972 or 1973 he gave me legal advice about the operation of a care home. [Handwritten addition: “He never charged for these services.”]
Tim Stoen often spoke as the Attorney for Peoples Temple in church services. I have heard him give legal advice and opinions on church affairs as well as on the affairs of individual members.
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FF-2-175A
Georgia Lacy
Profession: Housewife
Member since 1969.
Knew TOS since he joined.
Consultant about: real property matters in 1972 & 1973. Guardianship of children in 1974. Domestic relations problems with husband in 1975-1976. Advised on care home operation in Mendocino County in 1972 or 1973.
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FF-2-25A – 25B
Affidavit of ___, a.k.a Tish Le Roy: [handwritten insertion: “Laetitia”]
I first attended Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) services at the Embassy Ballroom in Los Angeles, in 1971. Soon thereafter I attended services in Redwood Valley. It was on one of those occasions that someone introduced Timothy O. Stoen (“Tim Stoen” or “Tim”) to me as the church attorney and the Assistant District Attorney for Mendocino County. I am skilled as a secretary, office manager, and full charge bookkeeper. During trips to Redwood Valley in the first half of 1972 I did legal secretarial work for Tim, and Gene Chaikin (sometimes “Gene”) as well when he was there on some weekends. I particularly remembered typing an offer to purchase real property dictated by Tim and Gene. It was complicated and took almost all night to complete.
Later in 1972, In August I believe, I and my family moved to Redwood Valley. I did so at the request of Tim Stoen and Gene Chaikin because there was so much legal work to do that they couldn’t get it all out. From that time on I have been a staff worker for the church. I worked primarily with Gene, but also with Tim, who used to work at night because he had his District Attorney job during the day. Tim also had other secretarial assistance, but with me, he usually listed Gene as attorney on most things, primarily he would say because of his job. Often Gene was never even there and Tim would instruct me to put Gene’s name on the letter, document or as attorney of record in cases that in fact Tim Stoen advised, strategized and dictated documents on.
On legal issues and on insurance matters Tim was always consulted. Even when Gene handled the matters, Tim was always consulted and insisted that on every occasion he review anything that Gene did before it would get out. Usually Tim wrote things out … he was not too good at dictation and there was always a first draft for him to correct if he had dictated a document. More often he would write out the first draft of the document, and dictate subsequent drafts from the corrected copy, often as he and Gene would discuss it.
There was always more legal work than I could ever keep up with. When Gene was in Guyana, Tim did all of the legal work for the church as well as all of the parishioners. He gave me a standard will form to use. I recall in all matters of the churches corporate minutes he dictated – or corrected the minutes I wrote myself from the meetings – and then signed them. During this time he advised on all financial purchases, legal issues, insurance matters for the church, disputes with vendors (for example the dispute with a vendor over a large purchase of bus tires which turned out to be defective), motor vehicle laws, and other regulations pertaining to the operation of the buses.
Later, when I did most of the accounting work for the church, I also had side jobs involving various church publications. I was in constant contact with Tim concerning these subjects. There was never a week went by that I did not confer with him—except when he was out of town. He personally read the paste ups of all publications and approved them before they were printed. In all of these activities he persisted until he left for Guyana in the early part of 1977.
[handwritten insertion: “Ok E.C”]
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FF-2-195
AFFIDAVIT OF DIANE LUNDQUIST
By profession I am a pre-school teacher. I became a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) in 1969, and I have known Timothy O. Stoen (“Tim Stoen”) since about that time, until 1977. Not long after I joined the church, I heard him describe himself as the attorney for Peoples Temple, in church services.
Around 1974, my son, Dov Mario Lundquist, was having problems in school. He was attending Calpella School in Mendocino County, California, and I was dissatisfied with the conduct of his teacher, which I felt was physically abuse of my child. I contacted Tim Stoen for his legal opinion about what I could do, and he asked me to come to his office in Ukiah. We talked about the matter, and he advised me to call the teacher. He gave me legal advice as to what I should say to her, what would be within my legal rights. I made the call in his presence and at his instruction.
[Handwritten notation: “OK E.C. 9/5 OK HT”]
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FF-2-139B
Diane Lundquist – preschool teacher
PT about 1969. Met TOS from about that time. He represented himself in church services as the attorney for PT, beginning not long after I joined the church.
Around 1974 my son Dov Mario Lundquist was having problems in school. He was attending Calpella School and I was dissatisfied with the conduct of his teacher, which I felt at the time was physically abusive of my child. I contacted TOS for his legal advice on what to do about the situation and he asked me to come to his office in Ukiah. We discussed the matter there and he advised me to call the teacher in question and instructed me as to what I should say to her, that would be within my legal rights. I made the call in his presence, following his advice. (I subsequently learned that, at the time, TOS represented the Ukiah Unified School District which included Calpella School.)
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FF-2-109
Affidavit of Magaline Lyles
I am a housewife. I have been a member of Peoples Temple of the Disciples of Christ from 1972 until the present. I have known Timothy O. Stoen (“Tim Stoen”) from that time until 1977. During that period, I was introduced to Tim Stoen as the attorney for the church, and I heard him introduce himself in like fashion in many public church services.
On several different occasions throughout 1975 I consulted Tim Stoen about obtaining my husband’s disability payments and Tim Stoen gave me legal advice on the matter.
Over the years Tim Stoen spoke as church attorney on numerous occasions, giving legal advice and opinions on church affairs during services and meetings held at various Peoples Temple churches. I heard him do this, myself.
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FF-2-175B
Magaline Lyles
Profession: Housewife
Member since 1972
Consultant several times on obtaining husband’s disability payments in 1975
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FF-2-197
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF EARNESTINE MARCH
By profession I am a nurses aide. I have been a member of Peoples Temple of the Disciples of Christ (“the Church”) since 1969, and have known Timothy O. Stoen from that time until early 1977. He was first introduced to me as the attorney for the church.
In late 1969 or early 1970 he gave me legal advice regarding divorce and the community property laws of the State of California. Over the years, I have seen Tim Stoen speak as attorney for the church in public services and meetings on many occasions, giving legal opinions and advice on church affairs as well as the affairs of individual members.
[Handwritten notation: “OK E.C. 9/5 OK HT”]
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FF-2-146A
Earnestine March – nurse’s aide
Rough 9/2 HT
PT since 1969/ known TOS since 1970.
He was first introduced to me as attorney for the church.
In late 1969 or early 1970, I sought his advice on a divorce from Alfred March. He gave me some legal advice about divorce proceedings and division of community property.
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FF-2-179B
Vicki Dover Marshall, 1974, 1974. TOS advised me on a guardianship proceeding before I became a member of PT and during the time I was a member of the Temple.
In 1976, he gave my grandmother, Nettie Jones, who was a church member legal advice concerning a car accident.
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FF-2-207
Affidavit of Estelle McCall
I am an insurance broker. I became a member of Peoples Temple of the Disciples of Christ in 1973, and I met Timothy O. Stoen in Houston Texas in 1973.
In 1973, he advised me on the procedure I would have to follow to get my daughter’s probation transferred from Houston to Los Angeles, Ca.
Again in 1976, Mr. Stoen gave me legal advice when my adopted child had been the subject of a kidnap attempt.
He also advised my daughter concerning her probation and prospective change of address in 1973.
[Handwritten notation: “OK EC 9/4 OK HT”]
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FF-2-185
Affidavit of Paul McCann:
I am a construction worker and I have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1973. I have known Timothy O. Stoen (“Tim Stoen”) since then. He was first introduced to me as the Attorney for Peoples Temple. He gave many members of Peoples Temple legal advice and help with their legal problems including myself.
In November or December of 1976 I was arrested on a burglary charge in San Francisco by the San Francisco Police Department. I was innocent. I subsequently discussed with Tim Stoen how the case could be handled to my best legal advantage. His advice was followed and the District Attorney dropped the charges after I had successfully completed a lie detector test showing that I had not committed the offense.
Frequently, over the years while in meetings at Peoples Temple I have heard Tim Stoen speak as church attorney and give legal advice and opinions concerning church affairs. I have also seen him giving legal advice to many, many persons after the conclusion of services. It was a regular part of a role he played in church.
[Handwritten notation: “OK E.C. 9/5 OK HT 9/5”]
—–
FF-2-151
Rough 9/2 Gene
I, Paul Michael McCann, being duly sworn, say:
By profession I am a construction worker. I have been a member of PT since 1973. I have known TOS since 1973 until 1977. He was first introduced to me as the attorney for PT. He gave many members of PT advice & help with their legal problems, including myself.
In November or December 1976, I was arrested on a burglary charge in San Francisco by the San Francisco PD. I subsequently discussed with Tim Stoen, how my case should best be handled to my legal advantage.
Frequently over the years while in meetings at PT churches, I have heard TOS speak as church attorney, giving legal advice & opinions concerning church affairs and the legal affairs of various members.
——
FF-2-146A
Rough 9/2 HT
Diana McKnight – cook
PT – 1973 – Known TOS since that time.
He was referred to me as the church attorney.
In June 1975 I sought and received legal advice from TOS in Los Angeles regarding obtaining legal custody over my younger brother, Kenneth, who was then in juvenile hall. He drew up a legal paper for my mother to get custody and spoke to the legal authorities on our behalf.
——
FF-2-152B
Rough HT 9/2
Ray Anthony McKnight – mechanic
PT – since 1975 – Known TOS since 1975.
He was first introduced to me as attorney for PT
In June 1975 I spoke with TOS about my brother Kenneth McKnight who was in juvenile Hall in Los Angeles. He advised us to get custody of Kenny and he told us what we should do, to get this done and we followed his advice.
—–
FF-2-224
Affidavit of Virginia Middleton
I am retired. I joined the Peoples Temple of the Disciples of Christ (“the church”) in 1973. In 1973, I became aware that Timothy O. Stoen was the attorney for the church when he announced in a meeting that he would be seeing people after the meeting who might need legal advice.
In 1973, he gave me legal advice concerning alimony payments that I was entitled to by court order.
[Handwritten notation: “OK EC 8/4 OK HT”]
—–
FF-2-225
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF CALLIE MITCHELL
I am a retired tailor and seamstress. I have been a member of Peoples Temple of the Disciples of Christ (“The Church”) since about 1973. I have known Timothy O. (“Tim Stoen”) Stoen from that time until he left for Guyana in early 1977. I was introduced to Tim Stoen as the attorney for the church.
In the Spring of 1975 Tim Stoen gave me legal advice about property left to me by my husband, John A. Mitchell, who had recently died. Tim Stoen filed a probate proceeding and later met with me at a courthouse in Los Angeles and he helped me straighten out some paperwork on the property. He gave me legal advice regarding my financial situation after my husband’s death. He also advised me on a number of business matters.
He made no charge for his services. They were given as part of the church program of meeting people’s needs, especially people like me who could never have afforded an expensive lawyer.
[Handwritten notation: “OK E.C. 9/4 OK HT”]
—–
FF-2-162
Rough 9/2 EC
Pamela G. Bradshaw Moton
By profession I am a practical nurse. I have been a member of PT since August of 1971. I have known TOS from that time until 1977 when he left for Guyana.
I lived in TOS’ house in Mendocino County, in 1971 (when Grace was pregnant with John) for a period of about 8 months. During that time TOS was the only attorney for the church. One room of his house was fixed up as a study and he spent almost every evening when there was no church services, working on church and member legal affairs in this office. The office contained hundreds of files.
When he was home, the phone would ring constantly, with people calling him about church and personal legal business. This would often continue until the small hours of the morning.
When my sister and myself sold our house on Holden Street, Ukiah, Mendocino County, he helped us with the transaction. He also gave me legal advice about dealings with my parents. I contacted him because I was concerned that they might attempt to force me to leave the church. He advised me on how to avoid this. It was of special concern when several conservatorships were handed down over young people in another church group.
——
FF-2-152A
Rough 9/2 HT
Russell DeAndrea Moton – agronomist & optician
PT – 1971 – Known TOS since that time. He was introduced to me as the attorney for PT.
2. About 1973 I spoke with TOS about the possibility of having a criminal record in Philadelphia expunged. He gave me legal advice on that matter.
In the fall of 1976 TOS was in Los Angeles and I spoke with him about a member of our church (Leo Wade) regarding an upcoming appearance in court. I was going to court with him as a friend and TOS advised me on what to do and what Leo Wade should do to see that things went well for him.
—–
FF-2-223
Affidavit of Cardell Neal
By profession, I am a school teacher. I joined Peoples Temple of the Disciples of Christ in 1970. I soon met Timothy O. Stoen who was introduced to me as the attorney for the Temple.
In 1972, I consulted Tim Stoen on my status as a perspective draftee and he gave me legal advice.
In 1974, he advised my mother on the legal procedure to follow when my brother was arrested.
[Handwritten notation: “OK EC 8/4 OK HT”]
—–
FF-2-179A
Hazell [Hazle] Newell
In 1974, he gave me legal advice concerning a loan on our house. In 1976, he gave me legal advice again concerning my children.
——
FF-2-226
[Handwritten notation: “Rough HT 9/2”]
AFFIDAVIT OF IDA MAY NICHOLS
I am a retired person. I became a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) in 1973. I have known Timothy O. Stoen (“Tim Stoen”) from that time, until the latter part of 1976. I was referred to him as the attorney for Peoples Temple by one of the members.
Around 1974 or 1975 I contacted Tim Stoen and he gave me legal advice about property that I felt I was entitled to. Tim Stoen explained my legal position and agreed to look into the matter on my behalf, which he did.
[Handwritten notation: OK. E.C. 9/4 HT OK”]
—–
FF-2-168
Rough 9/3 EC
Susan Jane Jerram aka Noxon
Profession: Licensed vocational nurse. Joined PT in 1971. Known Stoen since that date. Introduced as the lawyer for the church.
Consulted about employment & job recommendations, 1972. About an inheritance received from mother and stepfather, 1975.
TOS routinely gave members legal advice on Sundays in church, for several years, and being introduced from the pulpit numerous times as the church attorney.
——
FF-2-181
Affidavit of Beatrice A. Orsot, aka Beatrice Morton
By profession I am a legal secretary. I have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1970. I have known Timothy O. Stoen (“Tim Stoen”) since that time till early in 1977.
I was employed as a legal secretary for the Internal Revenue Service until the spring of 1976. At that time I retired on a disability and began to do volunteer work daily in the legal services office at Peoples Temple on Geary Blvd. in San Francisco. Also at that time Tim Stoen was a Deputy District Attorney in the office of the San Francisco District Attorney.
Our legal services office handled almost all of the church legal business, as well as the legal business of affiliated organizations, of many members of the church and indigent members of the community, all on a pro bono basis. Tim Stoen was a member of the staff and did legal work at our offices on evenings and weekends. We had a rotating system whereby he would be available to give legal advice to members of the congregation, which he did once a week. Each week we had staff meetings, usually on Friday nights. Those who usually attended were Tim, Gene Chaikin, Harriet Tropp, myself, and June Crym. During the summer, fall and winter Tim regularly attended those meetings, where all church legal affairs were discussed as well as the legal affairs of many members. Procedures, policies and case methods were discussed and implemented. All church corporate legal affairs were discussed in full. I took regular minutes at these meetings and followed up on the work assignments to see that they were completed on schedule. I particularly recall that at that time Tim Stoen was involved in church denominational and tax work. He also advised on members criminal matters, all of the legal considerations with respect to church publications, radio broadcasts and solicitation materials. He worked on auxiliary corporate organizations, read and approved minutes and other organizational materials.
page 1 of 1
[Handwritten notation: “OK E.C. 9/5 OK HT 9/5“]
—–
FF-2-150A
Rough 9/2 EC
Beatrice A. Orsot
My profession I am a legal secretary. I have been a member of PT since 1970. I have known TOS from that time until early in 1977.
I was employed as a legal secretary for the Internal Revenue Service until the spring of 1976. At that time I retired on a disability and began to do volunteer work daily in the legal services office at Peoples Temple, on Geary Blvd. in San Francisco. Also at that time TOS was a Deputy District Attorney for the office of the San Francisco District Attorney.
Our legal services office handled almost all of the church legal business, as well as the legal business of affiliated organizations, and in addition the legal affairs of many members (on a pro bono basis). TOS was on the staff and did legal work in the evenings at our offices, as well as his office. We had a rotating system whereby he would give legal advice to members of the congregation 1 day per week. Each week we had a staff meeting, usually on Friday nights. During the summer, fall & winter of 1976 he regularly attended staff meetings, where all church legal affairs were discussed, as well as the legal affairs of many members. Procedures, policies and case methods were discussed and implemented. All church corporate business was discussed. I took regular minutes of these meetings and followed up the work assignments
——
FF-2-150B
to see that they were completed on schedule.
I particularly recall that at that time he was involved in church denominational and tax work. He also advised on members criminal matters, all of the legal considerations with respect to church publications, radio broadcasts and solicitation materials. He worked on auxiliary corporate organizations, read and approved minutes and other organizational materials.
——
FF-2-23
Affidavit of Joyce Parks:
I am, by occupation, a registered nurse and Nurse Practitioner. I have been a member of Peoples Temple of the Disciples of Christ since 1949. I have known Timothy O. Stoen since he joined the church in 1969. Very soon after he joined , Timothy O. Stoen (“Tim Stoen” or “Tim”) became the attorney for the Church. He was the only person with legal knowledge in the congregation. He continued to function as the principal attorney for the Church until sometime in 1977 when he left.
During the years when Tim was our attorney the Church carried on a variety of free [illegible word] para-medical programs. Since there were many legal implications to this activity we always sought and received legal advice from Tim. He drew, at our request, a variety of authorizations, releases and other legal documents to facilitate our program.
Tim would also handle the legal affairs of many members of the Church. Frequently these matters were in connection with some established church program. For example, over the years the church has been very concerned with the care and protection of minority and disadvantaged children. Many members volunteered to raise such children. Tim Stoen consistently gave legal advice with respect to custody matters involving such children and represented the involved adults in Adoption and Guardianship proceedings or drew pleadings for them and told them how to represent themselves. In my case he represented my husband and myself in court for the adoption of my son J. Warren Parks in, as I recall, the last part of 1974 or early 1975. These child help programs were consistently referred by Tim as “church programs” and the church had a very good reputation in Northern California with respect to the care of children.
In the summer of 1973 I was at a church service in Los Angeles when there was a near riot in front of the church. As a result certain church members were detained by the police and two arrested. I was with Tim when he went to the police station in Los Angeles as attorney for the church, Rev. Jones, and certain members to represent those persons with respect to that incident.
(reference paragraph)
[handwritten insertion: “OK E.C 9/5, OK HT”]
—–
FF-2-138A
Joyce Parks
[Handwritten note: “Rough 9/2 Gene”]
I am by occupation a Registered Nurse and Nurse Practitioner. I have been a member of PT since 1949. I have known TOS since 19__ [last numbers of year blank] when he first joined PT. Very soon after he joined he became the attorney for the church. He was the only person with legal knowledge in the congregation. He continued to function as the principle [principal] attorney for the church till sometime in 1977 when he left.
During those years the church carried on a variety of para-medical programs. Since there were many legal implications to this activity, we always sought and received legal advice from TOS with respect to these activities. He drew, at our request, a variety of authorizations, releases and other legal documents to facilitate this program.
TOS would also handle the legal affairs of many individual members of the church. Frequently these affairs were in connection with established church programs. For example, over the years the church was very concerned with the care and protection of minority and disadvantaged children. Many members volunteered to raise such children. TOS consistently gave legal advice concerning the custody of such children, and represented the involved adults in Adoption and Guardianship proceedings. In my case he represented me & my husband in court for the adoption of my son, J. Warren Parks
——
FF-2-138B
in, as I recall, the last part of 1974 or early 1975. The child health services were consistently referred to by TOS and others as “church programs” and the church had a very good reputation in Northern California for the care of children.
In summer of 1973 I was at a church service in LA when there was a near-riot in front of the church. As a result certain church members were detained by the police and two arrested. I was with TOS when he went to the Police Station in LA as attorney for the church. Rev. Jones and certain members proceeded to represent those persons with respect to that incident.
——
FF-2-121
Affidavit of Leon Perry
I am a professional truck driver. I joined Peoples Temple in 1971. I met Tim Stoen in the same year; he was introduced to me as the attorney for Peoples Temple.
In 1971, I was involved in a truck accident and he gave me legal advice on the matter. I also consulted him around that time about a divorce and the possibility of bringing a civil suit for the failure of a contractor to repair my house properly.
——
FF-2-8A – 8C
Affidavit of Carolyn Layton Prokes:
I am by occupation a certificated secondary school teacher. I have been an active member of Peoples Temple of the Disciples of Christ (“the church,” “Peoples Temple”)”] since 1968. Over the years I have had many secretarial and administrative positions in the Church including a seat on the church Board of Directors. I have known Timothy O. Stoen (Tim Stoen) from 1969 when he joined the church till 1977 when he left.
During the period from 1970 to 1972, part of my responsibilities were in the area of banking and investment of church funds. During all that time, I frequently asked for and received advice from Tim Stoen concerning banking practices and the investment of church funds, as well as the legal effect of certain banking instruments, and the legal and tax consequences of various investments.
Often, usually bi-monthly, the Redwood Valley Congregation and the San Francisco Congregation would travel to Los Angeles for services there on the weekend, in a fleet of Greyhound-type busses owned and operated by the church. Tim, as I, would generally travel on the same Buss-No. 7- and I saw him do so dozens of times. He went for the purpose of giving legal counsel to members of the L.A congregation, which he would do during and after services. We routinely would have organizational meetings Saturday nights which Tim would regularly attend and give legal advice and opinions on various church projects and activities.
Several times he represented the church in situations where we believed that ex-members had taken funds or other property from the church (see addition). This representation included hiring and paying private investigators. He also represented the church in several instances when we believed that we had been libeled by the press, including sending letters, telegrams, and speaking with various persons. When outside counsel was employed in these matters they were selected by Stoen and supervised by him. On occasion the church adopted the tactic of filing a suit on behalf of some members rather than the corporation itself as in the case where Tim and Mike Prokes sued the columnist Lester Kinsolving. This was done on the legal advice by Stoen. The church paid the bill.
—–
FF-2-8B
Affidavit of Carolyn Layton Prokes: (Page 2 of 2)
Although Tim never received a salary or fees for his work for the church, as they were donated, three was some financial compensation. He received monies for travel expenses for church activities, and renumeration for gasoline and auto repairs. These various payments often amounted to $400 to $500 per month. He also received free room and board with a church member, arranged by the church, during the whole of 1976. Tim did make some financial contributions to the church while he was a member, but these were rather modest because he was always deeply in debt for school and other expenses that he had acquired before joining the church.
[handwritten addition: “OK EC 9/5”]
[handwritten note: “add meeting: TOS + Mertles [Elmer and Deanna Mertle, aka Al and Jeanie Mills]. add meeting: TOS + Joyce Shaw, late 1976”]
—–
FF-2-8C
Addition to Carolyn Layton’s affidavit
On one occasion he arranged that I go with him to Berkley, California for a meeting with Elmer and Deanna Mertle (aka Al and Jeannie Mills) who had left the church. We met the Mertles on Durant, near Shattuck Ave, in Berkley, by the Berkley public library. We walked to Shattuck Ave where there were some concrete type benches and sat down. Tim proceeded to write Mertles notes, rather than communicate orally with them, as he said they might be taping us. I do not remember the content of those notes. This was in late 1976.
Another time, in late 1976 or early fall of 1976, Tim Stoen, Harriet Tropp, and myself met another ex-member of the church at the apartment of Phyllis Houston at 998 Divisadero Street in S.F. The woman we met there was Joyce Cable Shaw. She had been living in the Midwest, but returned for the funeral of her husband, Robert Houston Jr. Tim again advised that nothing be said to her, except in writing. At the time, both Harriet and myself thought that this was ridiculous, since there was nothing improper about the content of the communication. Tim insisted however, and he produced a notebook with a message typed on one of the sheets inside, covered with plastic, For Joyce Shaw to read. As I best recall the message said something about our esteem for her late husband, and our hope that she would not try to pressure Mr. and Mrs. Robert Houston Sr. to take their grandchildren, Patricia and Judy Houston, out of the church. The children’s mother was a member of the church and still is. I think we were concerned that Joyce might attempt to persuade the grandparents to obtain custody over the children. Again, this was during the period of “Moonie” conservatorship cases, and we were concerned about that issue.
—–
FF-2-143A
Carolyn Layton
Rough 9/2 E.C.
I am by occupation a certified secondary school teacher. I have been an active member of PT since 1968. Over the years I have had many secretarial and administrative positions in the church including a position of the church Board of Directors. I have known TOS since he joined the church in 1969 or 1970, till 1977 when he left.
Part of my responsibilities were in the area of banking and investment of church funds. I frequently asked for and received advice from him concerning banking and the investment of church funds, the purchase of Certificates of Deposit and the like, and the legal consequences of various investments.
Often bimonthly the Redwood Valley & San Francisco congregations would go to Los Angeles on a fleet of buses for the weekend. TOS, as I, would generally travel on the same bus (#7). TOS went for the purpose of give [giving] legal counseling [to] members of the LA congregation which he would regularly do during services. During these weekends we routinely would have organizational meetings Saturday nights which TOS would regularly attend and give legal advice and opinions re: various church projects.
Several times he represented the church in situations where we believed ex-members had taken funds or other property from the church. This representation included employing and paying
——
FF-2-143B
private investigators. He also represented the church when, as several instances, we believed that we were libeled by the press, including sending letters, telegrams and talking to various persons. When outside counsel was employed in these matters, TOS was always the representative of the church with such outside counsel. On occasion the Church adopted the tactic of filing a lawsuit on behalf of members, rather than the Corporation itself, as in the case where TOS and Mike Prokes sued columnist Rev. Lester Kinsolving. All legal fees were paid by the Church. This was done on the basis of legal advice by TOS.
Although TOS never received a salary or fees for his legal work, there were financial compensations. He received monies for travel expense for church activities, funds for house payments and gas and auto repairs and to purchase automobiles. These various payments often amounted to $400-$500 per month. He also received free room and board with a church member, arranged by the church, during all of 1976.
TOS did make some financial contributions to the church, but these were very modest because during the time he was a member he was always deeply in debt for school debts and other debts he had when he joined the church.
——
FF-2-21A – 21C
Affidavit of Mike Prokes:
I first visited Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) in 1972. At that time I was employed by KXTV Sacramento as News Bureau Chief, Stockton, Ca. I had come to Peoples Temple to do a news stroy. One of the first persons I met there was Timothy O. Stoen (“Tim Stoen” or “Tim”)] who introduced himself to me as “the church attorney”, “Jim’s attorney”, and assistant District Attorney for Mendocino County.
I was so impressed with what I saw and heard about the humanitarian work of the church that I decided to join full time. I became a member of the church staff responsible for radio broadcasts and publications. I later also assumed the community relations function. From the time that I became a staff member till late in 1976, as an organizational procedure of the church, all of my working materials were given a “legal review” by Tim Stoen. Before publication or distribution.
In 1970 the church began to publish a periodical entitled the “Peoples Forum”. Tim, as the church attorney reviewed all material for legal clearance prior to publication. I would also seek and obtain legal advice form him with respect to the church structure and organization which I would then give out to the public officials and the media. He would also, often, give me legal advice as to the legal effect of public statements I would make on behalf of the church.
During the years 1973, 1974, 1975, and 1976 i was in very close contact with Tim Stoen and sought his advice, by his instruction, almost daily with respect to church business. I would call him at his office, at his home and also see him regularly at Church. He also gave advice concerning the organization of church volunteers to attend court hearings in support of certain causes, usually those involving members.
I was frequently present when he gave Rev. Jones advice about all matters of Church legal affairs including publications, media releases, corporate and denominational structure, tax, faith healing, and other topics. Eventually, all legal matters were left to Stoen and J.J though he received Stoen’s advice on everything. As the Church Attorney he was responsible for all legal relations and dealings with the denomination with which Peoples Temple is affiliated, the Christian Church of the Disciples of Christ. Virtually everything I did had some legal aspect which as Church Attorney he instructed me to check out with him, and I did so. [handwritten insertion: “There wasn’t a thing dad did that was done before consulting Stoen first. Constantly advised the Temple in all legal matters. J.J left all legal matters to him.”]
[Deleted paragraph: “All references in this affidavit to Tim Stoen are to the defendant Timothy O. Stoen. All references to “the Church” or to Peoples Temple are to the Plaintiff Peoples Temple of the Disciples of Christ, a California Corporation.
[handwritten insertion: “O.K E.C 9/5” “O.K HT 9/5”]
—–
FF-2-137A
Mike Prokes
[Handwritten note: “Rough 9/2 E.C.”]
I first visited PT [Peoples Temple] in November 1972. At that time I was employed by KXTV, Sacramento as a News Bureau Chief in Stockton, California. I come to PT to do a news story. One of the first persons I met there was Timothy O. Stoen, who introduced himself to me as “the church attorney ” and “Jim’s attorney” and as Assistant DA for Mendocino, California.
I was so impressed with the humanitarian service work on the Church that I decided to join full-time. I became a member of the church staff responsible for radio broadcasts, publications. From that time until February of 1977, all of my working materials as an organizational proceeding were reviewed and given legal approval by TOS before publication or distribution.
In 197_ [last number of year blank] the church began to publish a newspaper called “Peoples Forum.” TOS as the church attorney reviewed all materials for legal clearance for publication.
I would also seek and obtain legal advice from him with respect to information concerning the church structure and organization which I would then give out to public officials and the media. He would also, often, give me legal advice as to the legal effect of public statements I
——
FF-2-137B
would make on behalf of the church.
During the years 1973, 1974, 1975 & 1976, I was in very close contact with TOS and sought his advice almost daily with respect to church business. I would call him at his office, his home, and also see him regularly at church. He also gave advice concerning the organization of church members to attend court hearings for support & certain causes (and would use the facilities of his office to obtain information about certain persons, such as drivers license information, upon request.) [Marginal note: “? Omit”]
I was frequently present when he gave Rev. Jones advice about all matters of church legal affairs including publications, media releases, corporate and denominational structure, faith healing, tax exemption, and other topics. As the church attorney he was responsible for all legal relations and dealings with the denomination to which PT is affiliated, the Disciples of Christ.
Virtually everything I did had some legal aspect which, as church attorney, he instructed me to check out with him, and I did so.
——
FF-2-22
Affidavit of Eva Pugh:
I am a retired rest home operator, and have been a member of Peoples Temple (Originally the predecessor organization (“the church” “Peoples Temple”)) since 1953. I have known Timothy O. Stoen since he joined the Church sometime in 1969. I was the financial secretary for Peoples Temple from 1965 through 1976 and routinely received, banked, and disbursed Temple funds. I regularly got advice from Tim Stoen on how to handle bank accounts, how to keep books for the Church, and on my other duties. In fact he set up several bank accounts for the Church and also set up a simple set of books which I followed. He was familiar with all of the church financial affairs.
Over the years I gave him monies for various purposes: travel expenses and so forth. These expenses would often be 500 dollars per month. He received cash. Often he could not account for his disbursements, but at times gave adequate accounts. I never pressed him for receipts.
In 1976 my husband and I sold our rest home in Mendocino County, and a lawsuit was later filed against us with respect to the transaction. Tim assisted in the handling and disposition of the suit.
In 1976 he arranged with the Bank of America for me to be the signatory to deposit the checks of many of the members who had gone to Guyana, and also drew other financial documents with respect to banking for me. Once during 1975 or 1976 the church gave a man a check for $2500 as a deposit on the purchase of an airplane. The transaction proved a fraud and Tim helped to get the money back through bringing criminal charges against the man.
[handwritten insertion: “OK E.C, OK HT”]
—–
FF-2-155A
Rough 9/2 EC
Eva Pugh
Retired rest home operator. Member of PT since 1933. Known Stoen since 1968 or 1969.
I was the Financial Secretary for Peoples Temple from 1965 through 1976, and routinely handled and dispersed Temple funds. I routinely got legal advice from TOS on how to handle bank accounts, how to keep books of account and my other duties. He also set up a number of bank accounts for PT. Once TOS brought a set of books and set up the church financial books for me which I then followed. He was familiar with all of the church financial affairs.
Over the years I gave him moneys for various purposes: travel, expenses, and so forth. These expenses were often run $500-$600 per month. He received cash. Often he could not account for his disbursements but would also account at times for moneys spent. I never pressed him very hard for receipts.
In 1976 we sold our rest home in Mendocino County, and a lawsuit was later filed with respect to the transaction. TOS assisted me in the handling and disposition of the lawsuit.
In 1976 he arranged for me to be a signatory to deposit the checks at Bank of America, of many of the members who had gone to Guyana, and do other legal financial documents. [Illegible word] during 1975 or 1976, the church gave a man
——
FF-2-155B
a check for $2500 deposit on the purchase of an airplane. The transaction proved a fraud and TOS helped to get our money back through bringing charges in the San Francisco DAs office.
——
FF-2-186
Affidavit of Edith Roller:
I am now retired but have worked as an educator and as a secretary. I have been a member of Peoples Temple of the Disciples of Christ (“the church”) since 1970, and have known Timothy O. Stoen since that date as a fellow church member, as an attorney, and as a friend.
In 1973 he gave me legal advice to help me keep my then job at North Cast Opportunities, the Economic Opportunity Administration in Mendocino County. During the summer of 1974 he approached me and asked if I would be willing to make my will leaving all of my assets to the church. I agreed to do so. When Tim brought the will it showed him as the beneficiary. He explained that he was to be a “stand in” for the church, or a representative of the church. I signed it and it was witnessed. I did, and still do believe, that he was acting as a representative of the church and not for his personal interest.
[Handwritten notation: “OK E.C. 9/5 OK HT”]
—–
FF-2-156
Edith Roller
Profession: Educator, secretary. Member since 1970. Known TOS from that date.
TOS gave legal advice in 1975 to help her keep her job at North Coast Opportunities, the EOA office in Mendocino County. He advised her not to proceed and she was able to keep the job for some time.
During 1974 he approached me and asked me if I would be willing to make my will leaving my assets to the Church. I agreed to do so. When the will arrived, it showed TOS as beneficiary. He explained that he was to be a “stand-in” or representative for the church. I signed it, and it was witnessed. I did, and still do believe that he was acting as a representative for the church, and not for his personal interest.
——
FF-2-104
Affidavit of Annie J. Rozynko
I am a registered nurse. I became a member of Peoples Temple of the Disciples of Christ in 1970. I knew Timothy O. Stoen (“Tim”) before he came to Peoples Temple, as he was a friend of my husband’s. Around 1966 Tim was working with Mendocino County Legal Services. Tim, my husband, and I began going to services at Peoples Temple in Redwood Valley at approximately the same time. Soon after that, I became aware of the fact that he was representing Peoples Temple in legal matters.
I divorced my husband and around 1971 or 1972, he indicated that he wished to reduce child support payments. Tim advised me how best to handle the situation.
Again in 1973, Tim advised me on a legal matter. My mother died; I consulted Tim for advice regarding my mother’s estate and the execution of her will. He discussed the matter at length with me at the time.
In 1974 or 1975, my job at Medical Center Convalescent Hospital in San Francisco was in jeopardy, and I sought and received legal advice from Tim regarding the best way to secure my position with the hospital. He told me how to proceed in dealing with the administrator of the hospital, including preliminary steps to take regarding a civil suit against the hospital if that became necessary.
[Handwritten addition: “He advised and assisted me, as all Temple members, without charge.”]
——
FF-2-179C
Annie J. Rozynko, RN, 1970. Knew TOS before joining PT. He was a friend of my husband about 1966 while he headed Legal Services. [Balance of paragraph illegible]
Around 1971 or 1972, my husband wanted to reduce child support. I asked TOS’s advice on the matter & he gave me advice how to best handle the case.
Again in 1973 TOS advised me on a legal matter. In 1973 my mother and I went to TOS for advice on my mother’s estate. The execution of her will. He discussed the matter with me at that time.
Around 1974 or 1975, my job at [illegible word] County convalescent hospital in San Francisco was in jeopardy [Balance of paragraph illegible]
——
FF-2-117
Affidavit of Christian Rozynko
By profession I am an electrician. I became a member of plaintiff Peoples Temple of the Disciples of Christ (“Peoples Temple,” “the church”) in 1970. I knew Timothy O. Stoen (“Tim Stoen”) from about 1969 until 1977. He was very instrumental in my joining the church. Tim Stoen told me that he was acting as the attorney for Peoples Temple.
Over the years, my father, Vitali Rozynko, although divorced from my mother for some time, was continuously hostile towards the church, and my mother, brother, and sister’s participation in it. Periodically I consulted Tim Stoen on how the situation should be dealt with in the event he should attempt to use any legal device to restrict my participation in Peoples Temple. I received legal advice from Tim Stoen on what might be done if such an attempt were made, and how to avoid or prevent matters from reaching that point. More than once he indicated to me that there were other young persons in the church who feared a similar problem and that he and Eugene Chaikin had done considerable research on the subject, and that they were in a position to deal with it.
I also received legal advice from Tim Stoen regarding financial problems I was having. Tim Stoen gave legal advice to church members on a regular basis as part of the program of the church. He also publicly gave legal advice and opinions on church affairs as the attorney for Peoples Temple over the years. I have heard him give such advice and opinions myself.
——
FF-2-172
Rough 9/3 HT
I, Christian Leo Rozynko – electrician
PT – February 1970
I knew TOS since about 1969 and he was very instrumental in my joining the church. He told me that he was acting as attorney for Peoples Temple in addition to his job as Assistant DA for Mendocino County.
Over the years my father, Vitali Rozynko, although divorced from my mother for some time, was continuously hostile towards the church, me, my brother & sister & my mother’s participation in it. Periodically I consulted TOS on how the situation should be dealt with in the event he should attempt to use any legal device to restrict my participation in PT. I received advice from TOS on what might be done if such an attempt were made, on how to avoid or prevent it. More than once he indicated to me there were several young persons in the church who feared a similar problem & that he & Eugene Chaikin had done considerable research on the subject, and that they were in a position to deal with it.
I also received legal advice from TOS regarding financial problems I was having.
——
FF-2-111
Affidavit of Laurence Schacht, MD
My profession I am a medical doctor. I became a member of Peoples Temple of the Disciples of Christ (“the church,” “Peoples Temple”) in 1971, and I have known Timothy O. Stoen (“Tim Stoen”) from that time until 1977.
When I first came to Peoples Temple I had been a passenger in a vehicle involved in an auto accident. I had started a lawsuit, a claim for damages. I consulted Tim Stoen about the suit and he gave me legal advice.
I was in a number of business meetings over the ensuing years where Tim Stoen talk as the lawyer for the church, giving legal advice. I heard him discuss business transactions, the conduct of litigation, legal regulations, and give opinions on various laws and tax regulations.
——
FF-2-176A
Larry Schacht
Profession: MD. Joined PT 1971, knew TOS since then.
When I first came to Temple, I had been in an auto accident, I was a passenger. I had started a suit, claim for damages. Consulted TOS about the suit.
I was in a number of business meetings over the ensuing years where TOS taught as a lawyer, giving legal advice. I heard him discuss business transactions, the conduct of litigation, legal regulations, opinions on various laws and tax regulations.
——
FF-2-126
Affidavit of Debbie Schroeder
My profession, I am a schoolteacher. I have been a member of plaintiff Peoples Temple of the Disciples of Christ (“the Temple”) since 1972. I met Timothy O. Stoen in one of the meetings when he was introduced to me as the attorney for the Temple.
In 1974, he advised me to call the sheriff when my husband had gotten lost in the mountains for 24 hours.
[Handwritten PS: “Q: When did Jim joined the Disciples?”]
[Handwritten comment: “Out”]
——
FF-2-193
Affidavit of Rose J Shelton
I am a retired instructor of cosmetology. I joined Peoples Temple of the Disciples of Christ (“the Church” “Peoples Temple”) in 1967 and I have known Timothy O. Stoen (“Tim”) since he joined the church in 1969. He was introduced to me as the attorney representing the church.
I rode on the same bus as Tim on our regular bus trips to ad from Los Angeles, a period of the covering approximately 1971 though 1976. On each trip, Tim would work on legal affairs of the church papers and discuss legal affairs of the church with other members. He asked me on more than one occasion to keep the people on the bus quiet so he could do legal work. I prepared meals for him on the bus and he commented to me many times how much church legal work he had to do, in addition to his work for the District Attorney.
[Handwritten notation: “OK EC 9/5 OK HT”]
—–
FF-2-178
Rose J. Shelton – retired instructor of cosmetology –
PT 1967.
I knew TOS since he joined the church in 1969. He was introduced to me as attorney representing the church.
I rode on the same bus as TOS on our regular trips to and from Los Angeles, a period of time covering approximately 1971 – 1976.
On each trip TOS would work on legal papers and discuss legal affairs of the church with other members. He asked me on more than one occasion to keep the people on the bus quiet so he could do his legal work. I prepared meals for him on the bus and he commented to me many times how much church legal work he had to do, in addition to his work for the DA.
——
FF-2-132
Affidavit of Bonnie Jean Simon
I am a housewife. I have been a member of Peoples Temple of the Disciples of Christ (“the church,” “Peoples Temple”) since September of 1975, and I knew Timothy O. Stoen (Tim Stoen) from that time until late in 1976. He introduced himself to me as the attorney for Peoples Temple.
Periodically through 1976 I talked to Tim Stoen about my brother-in-law, Ray Simon’s divorce case. He gave me legal advice on the case, and agreed to handle the divorce. He drew up some papers and arranged a court date. Tim Stoen also gave me legal advice on a child custody matter. This advice and assistance was always given without charge, as part of the church program.
During the period I knew Tim Stoen, I would often hear him speak in Peoples Temple services and meetings as the attorney for the church, giving legal advice and opinion on church affairs as well as the legal affairs of various members.
——
FF-2-152B
Rough HT 9/2
Bonnie Jean Simon – bank teller & housewife
PT since September 1975 – knew TOS from that time. He was introduced to me as attorney for church.
In 1976 I talked to TOS several times about the divorce case for my brother-in-law Ray Simon. I spoke with him both at the San Francisco church and at the office in Ukiah. He agreed to handle the case for us and gave us advice regarding custody of my brother-in-law’s child. He also drew up some papers and arranged a court date for us.
——
FF-2-222
[Handwritten notation: “Rough HT 9/2’]
AFFIDAVIT OF EDRENA SMITH AKA DEE DEE SMITH
By profession I am a secretary. I have been a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) since about 1971 and I have known Timothy O. Stoen (“Tim Stoen”) from that time until late in 1976. I was introduced to Tim Stoen as the attorney for Peoples Temple.
As I best can recall, in the early Spring of 1976 Tim Stoen gave me legal advice about having a Peoples Temple member become my guardian. He directed June Crym, a legal secretary and a member of Peoples Temple to draw up the proper legal papers. He also gave me legal advice about how I should deal with my mother, so she would remain agreeable to my attending church, and not oppose the guardianship.
[Handwritten notation: “OK EC 8/4 OK HT”]
—–
FF-2-218
[Handwritten notation: “Rough HT 9/2”]
AFFIDAVIT OF GLADYS SMITH
By profession I am a nurses aide. I have been a member of plaintiff Peoples Temple of the Disciples of Christ, a Cal Corp (“the church”) since 1971 and I have known Timothy O. Stoen (“Tim Stoen”) from that time until he left for Guyana in the early part of 1977. I heard from different members that he was the attorney for the church, and he was introduced to me as such.
Sometime in 1976, my husband and I spoke with Tim Stoen about one of my children, who had been shoplifting. Tim Stoen gave us legal advice on how to handle the matter, so as to best help my son’s legal position.
[Handwritten notation: “OK EC. 9/4 HT OK”]
—–
FF-2-168
Ollie Maria Smith (aka Wideman)
Profession: Housewife. Joined PT 1972, knew TOS from then to 1976.
Consulted re: marriage. I was 16 years old and wanted to get married. Got legal advice from TOS how & where to get married legally out of California. Instructions on how to proceed, etc.
——
FF-2-219
[Handwritten notation: “Ask Gene?”]
Affidavit of Novella Sneed
By profession, I am a licensed vocational nurse. I became a member of the plaintiff Peoples Temple of the Disciples of Christ, a Cal Corp. (“the Temple”) in 1971; I met Timothy O. Stoen shortly after that when it was publicly announced by him that he was the attorney for the Temple.
He advised me concerning business some difficulty I was having receiving Medi Cal payments for patients in the nursing home I operated.
I was the operator of a 66? bed convalescent hospital in Pasadena, Calif with monthly accounts [illegible word, likely “received”] in excess of $ [number space blank] per month. Many of the patients were MediCal supported. In the spring of 1975, I began to experience difficulty in obtaining medical payments for the MediCal program. When the difficulty began to affect the financial strength of the business, I went to Timothy O. Stoen, as the attorney for the Church to get advice on how best to proceed. He advised me concerning the matter.
[Handwritten notation: “O.K. E.C. 9/4”]
—–
FF-2-105
Affidavit of Helen Snell
I am a retired person. I have been a member of Peoples Temple of the Disciples of Christ since 1971 and I have known Timothy O. Stoen since that date, and until 1977.
He gave many, many parishioners legal advice. I sought his legal advice about an auto accident case in 1975. We discussed my case, and he gave me his legal opinion. He referred me to an attorney in San Francisco to handle the case.
——
FF-2-175A
Rough 9/3 HT
Helen Snell
Profession: Retired
Member since 1971.
Known TOS since that date, stayed in his home as an overnight guest on several occasions.
Consulted: he gave many parishioners legal advice. Sought his legal advice about an auto accident case in 1975. He referred me to an attorney in San Francisco to handle the case.
——
FF-2-18
Affidavit of Carol Stahl:
By profession I am an elementary school teacher. I have been a member of Peoples Temple of the Disciples of Christ (“the church,” “Peoples Temple”) since 1968. Timothy O. Stoen “(Tim Stoen)” joined the church in 1969 and I have known him since that time until he left in 1977.
I have held a series of volunteer jobs in the church over the years, and several corporate offices and directorships, and am currently the Corporate President. Shortly after Tim Stoen joined the became the attorney for the church and really he was the main attorney down through the years. We did employ other counsel from time to time, and in 1972 Gene Chaikin joined the church and did assist him and handle the “free legal services” matters for the members form mid 1972 through the end of 1973, and again form mid 1975 through 1976, but Tim was always the one primarily responsible for Church business and corporate activities.
He was the principal person I would discuss church business with if it had any sort of legal implication. Under his direction I kept a whole series of legal documents relating to church and individual business and personal affairs.
I was present on one occasion on [in] 1976 when Maria Katsaris discussed her relationship with her father (i.e, that he had molested her) and her fears concerning him with Stoen, and heard him give her legal advice about it. He told her to stay indoors as much as possible and only go out with other people and if it looked like her father was going to move against her she could go to Guyana (get exact wording.) I was also present in a Los Angeles meeting of some of the key members of Peoples Temple in June or July of 1975 where Tim Stoen gave Rev. Jones advice concerning a proposed donation of real properties by Wade and Mabel Medlock to the church. He advised on how to handle the transaction “legally”, what should be said and not said and so forth. He, himself participated in obtaining the Medlock’s signature. He himself participated in the obtaining the Medlock’s signature on certain deeds. He was also present at another meeting at which I was also present with the Medlocks in the winter of 1976 where the gifts were discussed again and again advised how the transaction should be handled.
[handwritten addenda: “O.K E.C 9/5”; “O.K H.T. 9/5”]
—–
FF-2-153A
Rough 9/2 EC
Carol Stahl
My profession I am certificated elementary school teacher. I have been a member of PT since 1968. TOS joined in 1969, and I have known him from that date until he left in 1977.
I have held a series of volunteer jobs in the church over the years, and several corporate offices and directorships, and currently am the Corporate President. Shortly after TOS joined he became the attorney for the church and really he was the main attorney down through the years. We did employ other counsel from time to time, and in 1972 Gene Chaikin did assist him and handle “free legal services” matters for members during mid-1972 through the end of 1973, when Gene went to Guyana, and again from 1975 through 1976, but TOS was always the one primarily responsible for Church business and corporate activities.
He was the principal person I would discuss church business with if it had any sort of legal implication. Under his direction I kept a whole series of legal documents relating to Church and individuals’ business and personal affairs.
I was present on one occasion in 1976 when Maria Katsaris discussed her relationship with and fears concerning her father with TOS, and heard him give her legal advice about it.
——
FF-2-153B
I was present in a Los Angeles meeting with some of the key members of PT in June or July 1975 where TOS gave Rev. Jones advice concerning a proposed donation of real properties by Mabel & Wade Medlock to the Church. TOS advised on how to handle the transaction “legally,” what should be said and not said, how it should be handled, and so forth. He, himself participated in obtaining the Medlocks’ signatures on certain deeds which I subsequently understood were never used.
[Paragraph marked with question mark] He was again present at another meeting at which I also was present, in Los Angeles with the Medlocks in the winter of 1976, when the gifts were discussed and again advised how the transaction should be handled.
——
FF-2-228
Affidavit of Wanda Swinney: (1 of 1)
I am a bus driver, and have been a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”, “the church”) since 1968. I have known Timothy O. Stoen (“Tim Stoen”) since he joined the Church in 1969.
Over the years he gave me legal advice on a series of matters, both personal and community. I received advice about a custody matter in 1971, about a community Office of Economic Opportunity issue in 1971, and about a shooting incident in 1974.
During much of my time with Peoples Temple I was one of the drivers of our fleet of busses. Tim Stoen would periodically instruct us drivers on rules of the road, licensing and other regulations, and how to deal with the Police if we were stopped for any reason. He also advised on the rules and regulations with respect to the operation of the citizen band radios with which the busses were equipped.
[Handwritten notation: “OK E.C. 8/4 OK HT”]
—–
FF-2-221
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF CHRISTINE BOWERS aka CHRISTINE TALLEY
By profession I am a housewife. I have been a member of plaintiff Peoples Temple of the Disciples of Christ, a Cal Corp (“the church”, “Peoples Temple”) since about 1970 and I have known Timothy O. Stoen (“Tim Stoen”) from that time until about 1977. I was introduced to Tim Stoen as the attorney for the church by my sister, Marlene Wheeler.
Around 1974 I was living with my aunt who was not a member of the church. Tim Stoen gave me legal advice about different legal courses of action I could take to free myself from my aunt’s control. He gave me legal advice about my sister Marlene getting guardianship over me, so I could remain in the church.
I have often heard Tim Stoen, over the years, give legal advice and opinions as the attorney for the church, concerning church affairs, in Peoples Temple church services and meetings. He also gave legal advice to many. many members of Peoples Temple as part of the church legal service program.
[Handwritten notation: “OK E.C. 8/4 OK HT”]
—–
FF-2-149
Ron Talley
Rough 9/2 HT
My profession I am a sawyer. I am been a member of PT periodically since 1969. I have known TOS from then until 1976.
Over the years I asked him for legal advice concerning several matters: an industrial accident case in 1975; how to get information about any outstanding traffic warrants in 1972 (he told me to call the court representing myself as [illegible word] local attorney handling my case); concerning a traffic case in 1976. [Question mark in margin]
——
FF-2-110
Affidavit of Alma Coachman Thomas
I am retired. In September, 1971, I joined Peoples Temple of the Disciples of Christ (“the Temple”). I was introduced to Timothy O. Stoen as the Temple attorney in 1974.
In 1974, he advised me concerning eligibility for Aid to Defendant Children (which is now known as Supplemental Security Income).
In 1976, he advised me again concerning the transfer of real property.
—–
FF-2-92
Affidavit of Bernice Thomas
I am a retired practical nurse. I have been a member of Peoples Temple since about 1969 and I have known Tim Stoen from that time until about January of 1977.
I was referred to Tim Stoen by members of the Peoples Temple as the attorney for Peoples Temple. In 1972 Tim Stoen gave me legal advice about the purchase of real property in Redwood Valley with a G.I. loan.
In late Spring of 1975 Tim Stoen gave me legal advice regarding an offer I had received from a song publishing company in Los Angeles.
In 1976 I was involved in a car accident in San Francisco, California. Tim Stoen gave me legal advice about both the accident and the settlement of offer.
In 1976 Tim Stoen gave me legal advice about a claim I had against property in Weskom, Texas. Tim Stoen took the lease and some other papers from me and agreed to look into the matter for me.
Tim Stoen would speak as the church attorney, giving legal advice and opinions on church affairs during public church services at the Peoples Temple churches on many occasions over the years. He also advised individual members on their legal affairs as part of his regular function as church attorney. [Handwritten sentence: “He never charged for his legal work for Peoples Temple members.”]
—–
FF-2-217
AFFIDAVIT OF EVELYN THOMAS
[Handwritten notation: “Rough 9/2 HT”]
By profession I am a clerk typist. I became a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) in 1971, and I knew Timothy O. (“Tim Stoen”) Stoen from that time until 1977. He introduced himself to me as attorney for Peoples Temple.
Sometime in 1974, I was faced with the prospect of losing my job at Central Valley National Bank in Oakland. Tim Stoen gave me legal advice about retaining my job, as well as about my financial affairs.
Frequently in Peoples Temple meetings and services at the different churches, Tim Stoen would be called upon for his legal advice and opinions on church affairs. He would give legal advice and opinions, speaking as the attorney for Peoples Temple. I have heard him do this on numerous occasions.
[Handwritten notation: “OK E.C. 9/4 HT OK”]
—–
FF-2-147A
Rough 9/2 HT
1. Evelyn Thomas – clerk – typist
PT – 1971 – Known TOS since that time.
Intro as attorney for PT
2. Around 1974 I came to TOS for legal advice because I was about to lose my job at Central Valley National Bank in Oakland. I also asked his legal opinion about my financial situation. He advised me on these matters and gave me advice regarding bankruptcy proceedings.
——
FF-2-16
Affidavit of Charles Touchette
[handwritten notation: “Rough 9/3-H.T”]
By profession I am a sales engineer and construction superintendent. I became a member of Peoples Temple of the disciples of Christ (“the church”, “Peoples Temple”) in December of 1970. I have known Timothy Stoen since that time, until Spring of 1977. He introduced himself to me as attorney for the church at a meeting soon after I joined the church.
In September 1973 an incident occurred when Jim Cobb, my daughter Mickey Touchette, and others left the church. When they left, they took with them certain items that were not their property. Among those items, as I recall, were a hunting rifle, the property of one Tom Kice, a member of the church. In addition, they had vandalized Tom Kice’s property by tearing the phone out of the wall and doing other damage. Because I was very concerned about what they might do with the weapon, Tom Kice and I went to Tim Stoen’s office in Ukiah. Tim Stoen gave us legal advice on how to handle the situation so as to protect Tom, and how to make a formal complaint. On his legal advice and instructions I talked with one of the Sherrif’s deputies in Ukiah about the matter.
I moved to Guyana in July of 1974 with my family and I have been in Guyana since that time. I last saw Tim Stoen in the spring of 1977 in Jonestown Guyana. Tim Stoen was in Jonestown approximately two months. Twice weekly there were organizational meetings that Tim Stoen participated in and gave legal advice on purchases of businesses and real properties in Guyana; the resolution of sales disputes, lease hold obligations, and other matters.
[Handwritten notation: “O.K E.C, O.K [illegible, likely H.T.”]
—–
FF-2-173A – 173B
Rough 9/3 HT
I, Charles Touchette, sales engineer and construction superintendent.
PT – December 1970 – Known TOS since that time.
He introduced himself to me as attorney for the church at a committee meeting.
In September 1973 an incident occurred, when Jim C. [Cobb]. Mickey T. [Touchette] & others left the church. When they left, they took with them certain items that were not their property. Among other items were, a hunting rifle, the property of one Tom Kice, a member of the church. In addition they had vandalized Tom Kice’s property by tearing the phone out of the wall, defacing the wall and doing other damage. Because I was very concerned about what they might do with the weapon, Tom Kice and I went to TOS’ office in Ukiah. Tim Stoen advised on how to handle the situation, so as to protect Tom, and how to make a formal complaint. On his advice & instructions I talked with one of the Sheriff’s deputies about the matter.
I moved to Guyana in July of 1974 with my family and have been in Guyana since that time. I last saw Tim Stoen in the Spring of 1977 in Jonestown, NWD, Guyana. He was in Jonestown, approximately 2 months. Twice-weekly there were organizational meetings that Tim Stoen participated in and gave legal advice on purchases of businesses & real properties in Guyana (sawmill?)
——
FF-2-4
[Editor’s note: This is a rough draft, handwritten by Eugene Chaikin, of the affidavit of Harriet Tropp which appears below.]
—–
FF-2-19
Affidavit of Harriet Tropp:
I am a graduate of Hastings College of the Law, May 77. I am 28 years of age and have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1970. I have known Timothy O. Stoen (“Tim Stoen” or “Tim”) since that time. During the better part of 1976 and early 1977 I was a third year student at Hastings and a participant in Peoples Temple Legal Services program. Tim Stoen was part of the legal staff.
One problem of major concern to the law office during the fall of 1976 was the possibility of conservatorship orders being obtained against members of Peoples Temple, including Maria Katsaris. We did legal research on this issue, obtained copies of existing case records, and thoroughly discussed all of the points , strategies, etc., with Tim Stoen presiding. We discussed the case of each member we felt might have the family potential for this sort of litigation. Tim discussed the case of Maria Katsaris with which he was familiar & I heard from him that her father had molested her. He said Katsaris was “a real deviant motherfucker.” I said, “you mean about Maria?” (meaning he had sex with her). Tim said “16 years – pretty sick, huh?” or words to that effect. Shortly thereafter Tim made a report on the whole issue to a business meeting. He remained active in this program till he left for Guyana February of 1977.
I next saw Tim Stoen in Georgetown, Guyana in April of 1977, where I had gone with Eugene Chaikin to meet Tim Stoen and Rev. Jim Jones, Terri Buford, and Carolyn Layton for a legal conference that lasted three days (April 27-May 1). We met for from 16-20 hour days [illegible]. We thoroughly discussed the conservatorship issue. Tim again recommended that Maria Katsaris come to Guyana to avoid jurisdiction. He also recommended that need be, in order to protect herself, Maria should make public the fact that she had been molested by her father on several occasions. He said that he was not concerned with any sort of suit because he believed that Steven Katsaris (Maria’s father) would not be willing to be confronted by the truth in court. He described Katsaris using terms like “devilish bastard”, “cruel,” & “a smooth & convincing manipulator”. We discussed numerous other matters of church business at that time including future plans for the Guyana Mission Project, financing, transport of members, passport and custody matters, the specific problems of certain members and many other matters. Shortly after Gene Chaikin and I went back to California, Tim went with a group of persons from the church, including Rev. Jim Jones, to the island of Grenada on a church business project.
[handwritten insertion: “add 2nd addition on CL’s aff. [Carolyn Layton’s affidavit]”
H.T
—–
FF-2-14
Affidavit of Richard Tropp
By profession I am a college instructor in English. I have been a member of the plaintiff Peoples Temple of the Disciples of Christ, a Cal[ifornia] corp[oration], (“Peoples Temple”, “the church)” since 1970, and have known Timothy O. Stoen (“Tim Stoen or “Tim”) since that time.
During 1976 and 1977 Peoples Temple published a periodical entitled “Peoples Forum.” I had an editorial responsibility for the paper and wrote a considerable portion of the material. The printed material went through an organizational structure prior to being cleared for publication. Among these was a legal check because, or course, we wanted to avoid litigation which is always a risk in printing a periodical. Tim would be routinely given materials for legal clearance prior to publication and he would return the materials with such corrections as he might make and with his initials indicating his approval of the materials for publication.
In addition to the “Peoples Forum”, since 1973 the church also sent out a monthly solicitation mailer, printed notices of meetings, and other printed materials. Tim routinely cleared these materials for legal problems prior to their distribution, in the same manner as described above for the newspaper materials.
[handwritten notation: “O.K. E.C 8/4”]
—–
FF-2-145
Richard Tropp
Rough 9/2 E.
By profession I am a college instructor in English. I have been a member of PT since 1970, and have known TOS since that time, and until 1976.
During 1976 & 1977 PT published a periodical entitled Peoples Forum. I had an editorial responsibility for the paper and wrote a considerable portion of the material. The printed materials went through an organizational prior to being cleared for printing. Among those was a legal check because, of course, we wanted to avoid litigation which is always a risk in printing a periodical. TOS would routinely be given materials for legal clearance prior to publication and he would return the materials with his initials on them indicating his legal approval of the suitability of the material for publication purposes.
In addition to the Peoples Forum since 1973, the church also sent out a monthly solicitation mailer, printed notices of meetings and other matters. TOS routinely cleared all of these materials for legal problems prior to their distribution, in the same manner as described above for the newspaper materials.
——
FF-2-200
Affidavit of Rita Jeanette Tupper
[Handwritten notation: “Rough 9/3 JC”]
I am a housewife. I became a member of Peoples Temple of the Disciples of Christ (“Peoples Temple”) in 1971. It was periodically announced publicly in meetings that Peoples Temple members could go to Timothy O. Stoen (“Tim Stoen”) for legal advice.
Between the years 1971 and 1973, he advised me continuously during divorce proceedings against my husband. Before the divorce was finalized, I had temporary custody of my son Larry Howard Tupper. My husband took Larry one weekend and did not bring him home. Tim Stoen advised me [deleted words: “to go with Diana and Elmer Mertle to my husband’s parent’s house in Richmond, Ca and forcibly take the child.”] [handwritten insertion: “what to do to get my son back”].
Again, in conjunction with my son, my husband sent me a check for more than the amount of child support that had been ordered by the court, [deleted words: “I felt I should return the extra money but”] Tim Stoen advised me [deleted words: “to keep it all. The failure to give back the over payment led to my husband bringing a cause of action against me.”] [handwritten insertion: “what to do with”] it.
[Handwritten notation: “OK E.C. 9/5”]
—–
FF-2-179C
Rita Jeanette Tupper, housewife, 1971, 1971. It was announced in one of the PT meetings that we should go to him for advice.
Between 1971 to 1973, he advised me on my divorce. Before the divorce was finalized, I had temporary custody of my son Larry Howard Tupper. My husband took Larry one weekend and did not return him. Tim advised me to go to Deanna & Elmer Mertle to my husband’s parents’ house in Richmond, California and forcibly take the child.
——
FF-2-179D
Again in conjunction with my son, my husband sent me a check for more than the amount of child support the court has ordered. I felt I should return the money over the amount the court ordered, but TOS advised me to keep it all. The failure to give back the overpayment led to my husband [illegible word] a course of action against me.
——
FF-2-227
[Handwritten notation: “Rough 9/2 HT”]
AFFIDAVIT OF RUTH ANN TUPPER
I am a child care worker. I have been a member of Peoples Temple of the Disciples of Christ (“the church”) (“Peoples Temple”) since about 1970. I have known Timothy O. Stoen (“Tim Stoen”) from that time until the beginning of 1977.
My parents were separated when I was about 12 years old. About that time, my mother, brothers and sisters, and I became members of Peoples Temple. Periodically, my mother and I became concerned that my father, Lawrence Tupper, might try to obtain custody over myself and my brothers and sisters. On several occasions I consulted Tim Stoen for legal advice regarding what I should say to my father, and how I should conduct myself with him, and Tim Stoen gave me that legal advice. Tim Stoen also indicated to me that there were other people in the church with a similar problem and he had given them legal advice as well. Sometime in 1972 my father was threatening to take my mother to court in order to obtain custody. I spoke with Tim Stoen several times about what could be done to prevent this, and he gave me legal advice on what to say in court. He went over my testimony with me several times in order to prepare me for the hearing. At his direction I wrote a statement that was submitted to my father’s lawyer. Tim Stoen also consulted with Alan Davidson, a lawyer to whom he had referred my mother and myself, about the case.
I have heard Tim Stoen, over the years, speak in services and meetings of Peoples Temple, as the attorney for the church, and give legal advice and options on church matters in that capacity.
[Handwritten notation: “OK EC. 9/5 OK HT 9/5”]
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FF-2-157A – 157B
Rough 9/2 HT
Ruth Ann Tupper – childcare worker
PT since about 1970. I have known TOS since about that time. He was introduced to me as attorney for Peoples Temple.
My parents were separated when I was about 13 years old. About that time my mother, brothers & sisters became members of PT. Periodically my mother & I were concerned that my father (Laurence Tupper) might attempt to obtain custody over myself and my brothers & sisters. On several occasions I consulted TOS regarding what to say to my father & how to conduct myself, and TOS gave legal advice on these matters. He also indicated to me that there were other people in the church with a similar problem and he had given them legal advice as well. Around 1972 my father was threatening to take my mother to court in order to obtain custody over us. I spoke with TOS on more than one occasion on what to do to prevent this and he gave me legal advice on what to say in court to protect my interest in preventing gaining custody. He went over my testimony with me several times. At his direction I wrote the statement which was submitted to my father’s lawyer, Michael B. [Blank space] of Oakland. TOS also consulted with Alan Davidson, who Tim had referred my mother and I to about the case in Redwood Valley.
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FF-2-179A
Gary Lee Tyler, March 1973, 1975. He told my mother Jesse May Skaggs [balance of entry illegible]
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FF-2-179B
Inez J. Wagner, 1969, 1970. He was introduced to me as the church attorney.
In 1971 he advised me regarding the sale of my home for the aged in Rincon Valley near Santa Rosa. In 1975, he advised me regarding the custody settlement of my son, Mark Wagner.
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FF-2-179F
Annie B. Washington, retired nurse’s aide, 1974, 1975, introduced to me as attorney for PT.
In 1976, TOS gave me legal advice concerning $ owed to me by my employer.
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FF-2-189
Affidavit of Eddie Washington
[Handwritten notation: “Rough 9/3, JC”]
I am retired. In July 1972, I joined Peoples Temple of the Disciples of Christ and in October of that year I was told that anybody needing legal advice should see Timothy O. Stoen.
I consulted him about criminal charges that were pending against one of my tenants. In 1974, he told me what to do when I was threatened with foreclosure of my property.
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FF-2-179D
Eddie Washington, July 1972, October 1972. I was told that anybody who had any legal matters should see TOS. He gave me legal advice on the matter of criminal charges pending against one of my tenants.
In 1974, he advised me in the matter of the impending foreclosure on a piece of property I owned.
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FF-2-212
[Handwritten notation: “Rough 9/3 HT”]
AFFIDAVIT OF MARLENE WHEELER
By profession I am a primary school teacher. I became a member of plaintiff Peoples Temple of the Disciples of Christ, a Cal Corp (“Peoples Temple” “church”) in 1970. I have known Timothy O. Stoen from sometime in 1969. He introduced himself in public church services as the attorney for Peoples Temple.
In 1971 I consulted with him about my status as a welfare recipient. He gave me legal adv ice as to my rights, and as to what course of conduct would be in my best legal interest.
[Handwritten notation: “OK E.C. 8/4/78 OK HT”]
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FF-2-169A
Rough 9/3
Marlene Diane Wheeler, primary school teacher, PT 1970. Knew TOS since about 1969. He introduced himself in public church services as attorney for the church.
In 1971 I saw him after a church service at Redwood Valley and asked his legal opinion regarding my status as a welfare recipient. He discussed my situation and he advised me as to my legal rights and what course of conduct I should take.
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FF-2-183
AFFIDAVIT OF JOSEPH WILSON
By profession I am a construction worker. I have been a member of Peoples Temple of the Disciples of Christ (“the church”, “Peoples Temple”) since 1971. I have known Timothy O. Stoen (“Tim Stoen”) since that time, until 1977. He was introduced to me as the attorney for Peoples Temple.
In 1971 I discussed with Tim Stoen the procedure for getting my criminal record in New Jersey expunged. We discussed the facts of my case and he gave me legal advice on how to proceed, and told me he would work on getting the matter straightened out.
Around 1975 a warrant was issued for me on traffic violations in Los Angeles County. I asked Tim Stoen for legal advice, which he gave me, regarding what to say and how to conduct myself in court. Again in 1975 I was in Santa Rose, California when a friend and I were mobbed by a group of persons. I was to appear as a witness in a criminal trial arising out of that incident. The church was very concerned about the incident, as it had racial implications and occurred during a trip on a church owned and operated bus. The church felt that this was an attack on Peoples Temple as a multi-racial organization and was very involved in assisting the prosecution. Tim Stoen spent many hours with me, discussing the case and preparing me to testify.
In 1976 I had an altercation with the police in Ukiah, California. I went to Tim Stoen’s office in Ukiah several times and asked his advice on what I should do, so that the matter would be handled to my legal advantage, which advice he gave me.
Frequently, over the years, while in church services or meetings, at Peoples Temple Churches, I have heard Tim Stoen speak as the church attorney giving legal advice and opinions concerning church affairs and the legal affairs of various members.
[Handwritten notation: “OK EC 9/5 OK HT”]
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FF-2-142A
Joseph Lafayette Wilson – construction
Rough 9/2
PT 1971. I knew TOS from 1971. He was introduced to me as attorney for church.
In 1971 I discussed with TOS the procedure for getting my criminal record in New Jersey expunged. We discussed the facts of my case, and TOS gave me legal advice on how to proceed, and told me he would work on getting the matter straightened out.
About 1975 there was a warrant out for me on traffic violations in LA County. I asked Tim Stoen for his legal advice and he advised me to turn myself in and he gave me legal advice as to what to say and how to conduct myself in court, which advice I followed.
In 1975 I was in Santa Rosa, California when a friend and I were mobbed by a group of persons. I was to appear as a witness in a criminal trial arising out of that incident. The church was very concerned about the incident, as it had racial implications and occurred during a trip on a school owned & operated bus. The church felt that this was an attack on PT as a multi-
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FF-2-142B
racial organization and was very involved in assisting of the prosecution in the hope that it might forestall future outbreaks of racial violence. TOS spent several hours discussing the case with me and preparing me to testify in the case.
In 1976 I had an altercation with the police in Ukiah, California. I went to TOS’s office in Ukiah several times and asked his advice on what I should do. I told him the facts of the case and he gave me legal advice on what I should do so the matter would be handled to my legal advantage.
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FF-2-220
Affidavit of Peter Wotherspoon
I am a school teacher. I have been a member of plaintiff Peoples Temple of the Disciples of Christ, a Cal Corp (“Peoples Temple”, “the Temple”) since 1971. I met Timothy O. Stoen in 1971 when he introduced himself to me as a member of Peoples Temple and the attorney for the Temple.
In 1975, he advised my wife and I in the proper procedure for the purchases and later transferring of real property in Calpella, Ca. He was my next door neighbor from 1971 through 1973, and I saw him almost daily working on Peoples Temple affairs at his house.
[Handwritten notation: “OK EC 8/4 OK HT”]
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FF-2-119
Affidavit of Johnnie Mae Yates
By profession I am a physical therapist. I have been a member of Peoples Temple of the Disciples of Christ since 1970 and I have known Timothy O. Stoen from that time until 1977. He was introduced to me as the church attorney.
In 1973 I was injured in a car accident and I consulted Tim Stoen about the possibility of bringing suit. He gave me his legal opinion on the matter and advised me about the steps I would have to take. He then referred me to a lawyer in Los Angeles.
In 1974 I consulted Timothy O. Stoen about back surgery I had had, and the possibility of bringing a suit for medical malpractice. He gave me legal advice on that matter as well.
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FF-2-175C
Johnnie Mae Yates
Profession: physical therapist
PT 1970 – Known TOS from that time as the church’s attorney.
Consult: In 1973 I was injured in a car accident, sought his legal advice about car accident and after hearing the facts, referred me to a lawyer in Los Angeles.
In 1974 I sought his advice regarding a surgery I had on my back, and the potential for a medical malpractice suit. He gave me legal advice on that matter.
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Miscellaneous notes for potential affidavits
FF2-234
He gave Dorothy Worley legal advice about her divorce. She was in P.C. meetings when he was there & Dorothy & Christine Young were present & marched around the Examiner.
(Paula)
Chaikin, I don’t know if it was you or TOS that advised us on where to go, what to do & what to say in Ukiah Courthouse when Chris stole a car. (Neither does Harold [Cordell]
Loretta Cordell
Also was he there to give advice to go to LA & find Monique’s mother for her to be able to come over here. We needed the papers signed & we (Annette Jones & myself) were told to go to LA & find her to sign the papers.
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FF2-243
Tim Stoen advised Tom Kice and myself how to act and what to say to the sheriff when we went to the sheriff about the Pepsi-Cola six (Jim Cobb – Mickey T.) when they split and took a gun and money from us
He also knew that I was wired for sound. This was September 1973.
Charlie Touchette
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Notes of conversations of Temple staff discussing the campaign for affidavits
FF-2-1A
8/29/78
To: Harriet Tropp
Fr: Bea Orsot
RE: Tim Stoen
Since it was requested last night for everyone who had received legal advice to submit their names, I thought it would be best for me to review the entire list & pick out which cases are relevant to the time I was in the law office.
Other points which I feel may be important are as follows:
- Apostolic Corporation (see Tish)
- Conscientious Objector Cases, specifically, he helped my son, Antonio Harvey, get that status when I first came in church in 1970.
- Chris Lewis
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FF-2-1B
(4) IRS, FBI.
Advice sought on our obtaining files on PT & Jim Jones under Freedom of Information Act.
(5) I think he was involved in a visit to a place like “Mission Impossible” by us. Don’t know if this is relevant. Not working in law office. Unfamiliar.
(6) People’s Forum
(7) John Brown
Adoption by Jim & Marcie
(8) Relics & Things
(9) Lois Ponts
Real estate
Child custody
(10) Debbie Evans
[two illegible lines]
(11) Melissa Jackson
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FF-2-127A – 127D
Handwritten notes for affidavits
[Abbreviations and shorthand notes, where decipherable, are spelled out below]
1. Maria K. [Katsaris]
A. Conversations with TOS [Timothy O. Stoen] in San Francisco fall 1976;
– ask advice
– what he advised her on
B. General Facts – TOS gave legal advice, court appearances, familiar with her case, Medlocks, Cobb, etc.
C. Knew TOS and Grace – says John is Jones’ child
D. [Illegible word] meetings TOS gives legal advice
E. Finance – always instructed to go to TOS for legal advice, [Illegible word] to church matters – as late as fall 1976 had asked and received advice regarding church legal matters & had always received it
F. She came to Guyana [Illegible word] pursuant to his advice, because of father conservatorship. Only one way of avoiding – removed from jurisdiction of courts
G. Being better that he (TOS) [Illegible word] she told him in confidence. Trepidation is of returning to US especially because he now represents her father, but ready and willing to give deposition and Guyana concerning [Illegible word] matter
H. Present when TOS advised regarding Medlocks (perhaps)
II. June Crym
A. Law office – TOS present – describe [Illegible word]
– advice on Medlocks
– other matters
B. Generally described his role as attorney for Peoples Temple as she saw it in her role as legal secretary from Mendocino days on down. She should describe in detail the kinds of matters he dealt with based on her taking his dictation for years – Property transfers
C. Describe research that went on around time of [Illegible word] and specific descriptions of Maria’s case
D. TOS’s general level of knowledge concerning Temple affairs. Also about John.
III. Harriet Tropp
A. Background – UC Berkeley, [Illegible word, could be “Hastings,” UC law school ] research assistant law clerk
B. TOS’s general background and activities – Cobb, Medlock, or Katsaris (specifically the April meeting)
TOS talked to Medlock about their property transfer on behalf of church
C. John – Jim’s child ([Illegible word] TOS & Grace)
IV. Clara Johnson
– hospitality to Medlocks
– she had extensive discussion with them. They told her that TOS had come to them and solicited that they sue the church
– Present at meetings in LA when TOS, acting as an ally for Peoples Temple, discussed transfer with Medlock’s
V. Jim
A. For years Pres. of corporation and TOS conducted all the legal affairs for church and Gene [Chaikin] assisted him. Had intimate knowledge.
– Jim consulted him on all legal issues, took his advice
– specifically with respect to proposed Medlock gift, TOS advised it would be legally sound to accept & suggested methodology & appropriate documentation be used
– TOS handled every aspect of legal work of church and many of its members
[Fold in page makes paragraph illegible]
Bank of America Ukiah Branch #127 (Ask: TOS if signatory on any account) – copy of bank card – a children’s concession stand in Ukiah. Asked if any other accounts he had his name on.
[2 lines in capital letters] Some of dead real estate files signed by TOS as chairman of the board. Early tax files may have declarations signed by TOS.
V. Jim
Maria consulted him as a pastor and father, and Jim consulted with TOS as lawyer concerning pastor church as officer might take and receive legal advice from him – in April 1977 meeting
Ask Bea [Orsot]: All about TOS Law office, see what she remembers
VI. Tish [Leroy] and bookkeeping
– constantly consulted TOS regarding how different business records should be kept
– advice concerning certain tax matters with respect to the church
– insurance – responsible for insurance – gave legal advice to TOS
KAY [Nelson]: Ask whether TOS ever advised her regarding any real estate transactions
June: should check out lawsuits in Mendocino County that TOS did for Peoples Temple
VII: Richard Janaro
– how long member
– Ranch. TOS activities also with respect to operator involved in [illegible word] for Peoples Temple
– TOS handled lawsuit
VIII. Prokes:
– advised both legally and otherwise regarding public relations
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FF2-241
June Crym:
* bring her examples of rough drafts of TOS letters where signed as counsel, letters, especially rough drafts of pleadings or corporate documents.
* not many – but covering a span of years
* names of cases he represented PT on
* some case files & law office reports
tax affidavits – TOS signed some.
Bring Medlock files – anything – original deeds –TOS handwritten paper, listing agreement
* Ask Frolich about dealing with TOS as counsel for PT.
* LA apartment deal: Check lawsuit we had against the owner –TOS and part of that deal (closing the transaction) and LA apartment file (in closed real estate file, there are handwritten instructions by TOS
June Crym
affidavit – very detailed detailing role as attorney – her role as legal secretary from Mendocino days down/kinds of matters he dealt with based on her taking his dictation for years – describe research on Moonie cases & specific decisions re: Maria [Katsaris] cases