Summons, September 20, 1977

1977 • No. 2584 • DEMERARA

IN THE HIGH COURT OF THE SUPREME COURT OF JUDICATURE
CIVIL JURISDICTION

In the matter of JOHN VICTOR STOEN,
an infant

-and-

In the matter of an application by
GRACE LUCY STOEN by and through her
Lawful attorney Jeffrey A. Haas, for
a Writ of Habeas Corpus and Sub judiciem,

-and-

In the matter of the Civil Law Act, Chapter 6:01

SUMMONS

Page 1

1977 • No. 2584 • DEMERARA

IN THE HIGH COURT OF THE SUPREME COURT OF JUDICATURE
CIVIL JURISDICTION

In the matter of JOHN VICTOR STOEN,
an infant

-and-

In the matter of an application by
GRACE LUCY STOEN by and through her
Lawful attorney Jeffrey A. Haas, for
a Writ of Habeas Corpus and Sub judiciem,

-and-

In the matter of the Civil Law Act, Chapter 6:01

SUMMONS:

LET ALL PARTIES concerned attend the Judge in Chambers at the Law Courts at Georgetown, on Friday the 23rd day of September, 1977, at 9 o’clock in the forenoon on the hearing of an application on the part of JOYCE TOUCHETTE for the following:

(a) An Order that Joyce Touchette of Jonestown, Port Kaituma, North West District, Kaituma, be added and joined as a Respondent/Defendant in this said Cause or Matter as a person directly interested and concerned in the same and as a person who has been affected and will be affected by all Orders made or to be made in this said matter.

(b) An Order that the Orders of His Honour Mr. Justice Bishop (in chambers) made herein on the 6th day of September, 1977, 8th day of September, 1977, and the 10th day of September, 1977, be declared void and/or a nullity and/or of no effect and be set aside ex debito justitiae.

(c) A declaration that the procedure adopted in respect of the service of the Writ of Habeas Corpus on Reverend Jim Jones and/or the alleged making of John Stoen a Ward of Court and taking him into custody, and/or the grant of leave to commence Contempt proceedings against Reverend Jim Jones, and the Orders in connection therewith are all irregular, contrary to the Rules observed by the Courts of Guyana and contrary to Laws of Guyana and contrary to the Rules of natural justice, and are an abuse of the process of the Court and are a nullity and should be set aside ex debito justitiae as a nullity, and contrary to Article 5 of the Constitution of Guyana, Chapter 1:01.

(d) A declaration that the proceedings by Writ of Habeas Corpus in which Reverend Jim Jones is not even named as a Respondent/Defendant

-2-

are bad for want of jurisdiction, of the High Court of the Supreme Court of Guyana.

AND the cost of this application may costs in the action.

/s/ [illegible]

DATED this 20th day of September, 1977.

This summons was taken out by Mr. Mohammed Ayube Ally McDoom, Solicitor of McDoom & Company, Legal Practitioners, 2 Croal Street, Georgetown, Demerara, for the Applicant herein, who resides at Jonestown, Port Kaituma, North West District.

To: The plaintiff

and

Mr. H.B. Fraser
Solicitor,
Hughes, Fields, and Stoby
Legal Practitioner,
62 Hadfield & Cross Streets
Georgetown, Demerara