FF-12-A-63
ROUGH OF GENE’S [Chaikin] AFFIDAVIT
As I best recall now, the first time that I attended Peoples Temple church, which was in January of 1972, at that time, having been a licensed attorney of law in California for some eleven years, I was employed by the County of Shasta as the Deputy County Counsel. Some of the first persons I met upon going to the church were Tim and Grace Stoen. Timothy introduced himself to me as the Chairman of the Board and the principal legal counsel for the People’s Temple, and also an Assistant District Attorney for the County of Mendocino, in charge of civil matters – a position roughly equivalent to the one that I held in Shasta County at the time. Subsequently until the summer of 1972 I continue to live and work in Shasta County and attended the church frequently. One of the persons whom I got with more than any other was Tim Stoen. He functioned as the chief legal counsel for the church and I worked as his assistant, principally doing free legal work for various indigent persons as a result of the church legal services program. During the summer of 1972 I moved to Mendocino County and became affiliated with the church on a voluntary, non-paid, full-time basis, every charge of the legal services program. My relationship continued to be one of an assistant to Tim Stoen, who acted as chief legal advisor for the church. This relationship continued until approximately the 30th day of December, 1973 when I left for Guyana, South America to work in the church’s agricultural project. I remained in Guyana, S.A. until, as I recall now, until the end of August 1975. During that period of time Tim Stoen was the sole legal counsel for the church, taking care of all matters, including matters relating to the legal services program. On my return to the US I again began to serve as counsel for the church, and work in that position with Tim until sometime in the late spring, early summer of 1977, when he appeared to have severed his connection with the church.
During the time that I worked with Tim beginning in 1972, he handled many real estate transactions for the church, including the purchase of real properties in Mendocino County, San Francisco, and Los Angeles. He organized and set up bank accounts for the church and was personally responsible for handling church funds and, in addition, funds of some members of the church in an individual capacity. He wrote several revisions of the Articles of Incorporation, and together with myself did a complete revision of the By-Laws of the church encompassing a reorganization of the entire church structure. He continuously acted as the counsel for the church and representative of the church with the denominational organization of the Disciples of Christ, which denomination PT is a member. In this regard he contacted attorneys for the Disciples of Christ organization, wrote numerous letters, attending conferences, and in other ways represented the church as an attorney. During the course of my experience with Tim there were several lawsuits in which the church was involved. I recall one rather lengthy suit which involved a real property dispute which Tim solely handled for the church. In another lawsuit in Mendocino County which he also handled. (HAVE TO GET NAMES OF SUITS HERE.) As a 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. In addition to more formal Board meetings which usually ratified the activities that were discussed informally in these assemblies. They continued from sometime in the early spring of 1973 through roughly June of 1977. Tim attended all of those meetings regularly, and in each meeting gave legal advice concerning matters that were broached that have legal implications. In this way he became intimately familiar with all 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 then had some 20,000 members, maintained three independent church structures with three independent congregations, maintained a fleet of eleven Greyhound buses which it serviced itself, regularly moved to that caravan all over California and annually all over the US, that had income a sum of several hundred thousand dollars yearly); very difficult to imagine a person who was more intimately familiar with the affairs of the church than Timothy Stoen. He served as the chairman of the Board of Directors of the church for a number of years, and gave the Board legal advice.
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He wrote numerous letters to various persons with respect to legal activities of the church, he filed tax returns with the state of California and tax declarations with several counties in the State, signing them as the attorney for PT church. (NOTE: THOSE should be available in Mendocino, possibly in SF and LA as well.)
Amongst other things he gave legal advice concerning the acceptance by the church donations from members. From time to time, members made large donations to the church, including donations of real properties. Among others was the donation by the Medlocks, of two pieces of real property in the County of Los Angeles. At the time that the Medlocks were first contemplating making these gifts, the matter was discussed in great detail with Tim in his legal capacity because, especially Mabel Medlock at first was extremely ambivalent about making the gift. Mr. Medlock always took the position that he was very, very anxious to do that, he had no further use of the property, and he wanted to go where it would do some good. But his wife, Mabel was always extremely ambivalent. As a result there were discussions concerning the implication of the gift, but also recommending that they do be accepted. But also in terms of the kind of documentation that he felt would be appropriate. He gave legal advice specifically. As the transaction continued and Mrs. Medlock – although she did in fact did execute a number of documents effecting a transfer of title to the church – continued to be ambivalent about the transaction. Tim was consulted a number of times concerning how the transaction should be handled, whether the gift in effect should be accepted, whether the property should be reconveyed, and so on. He was and is intimately familiar with all aspects of the transaction. During 1973, the latter half of 1975, and into the middle of 1976, periods of time in which I have firsthand knowledge, Timothy Stoen would travel with the church congregation to Los Angeles where the Medlocks resided at least once a month and often twice a month, and would therein as well as in SF give legal advice to many, many members of the congregations, and a number of times in my presence spoke to Wade Medlock, and more than once spoke to Mabel Medlock concerning their property transaction.in this way, he not only became aware of their situation with the situations of hundreds and hundreds of persons who he counseled over periods of time, in some instances with respect to transactions that involved the church.
As a result of participating in the church legal services program and counseling these numerous people he became intimately aware of the lives and activities of hundreds of persons.
Tim was especially close to persons who had more intimate organizational connections with the church. An example is Maria Katsaris. In my presence Maria spoke to Tim several times concerning her concern about her father, her concern that he might attempt to get a conservatorship over her. These concerns were especially voiced during the period of the so-called “Moonie” cases on which conservatorships were being imposed ex parte in both San Francisco and Alameda counties, and he consulted with her several times concerning this and concerning her relationship in my presence. He also discussed the matter with me and several other persons connected with legal affairs in the church. During the latter part of 1975, and 1976, into early 1977, there was a law office established on the premises of the church in SF. There were a number of persons who work together in this office, handling church business and also handling clients’ affairs as part of the legal services program. Among others for myself, June Crym, Harriet Tropp who was then a law student, Bea Orsot who was a legal secretary, and several others. Weekly meetings were held which were called “Law Office Meetings.” Tim attended practically all of those meetings. At those times we discussed a regular agenda of church business and clients’ affairs. Tim participated in these discussions and drafted documents, dealt with transactions, work with cases as an attorney for the church and as an attorney for a number of members of the church.
The last time I recall seeing Tim Stoen was in April of 1977 in Georgetown, Guyana where he was at that time located working with church activities and doing legal work for the church in Georgetown with respect to the church project. I went down for a few days to meet him. There was a meeting which continued for three or four days at which time the whole Katsaris case – Maria’s situation, her situation with her father, her concern with the conservatorship proceeding that she felt her father might try to place on her, the sexual problem she had with her father, the possibility of using that information in the event that he should appear to unduly interfere in her life, were thoroughly discussed, and Tim in fact advised
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on that occasion that her relationship with her father, and the problems she had with him, especially of a sexual nature, be disclosed in the event that he would insist on seeing her, meeting her against her wishes and doing the sorts of things that would ultimately put pressure on her and force her to live according to his wishes and views. On that occasion Tim advised, as he had advised on previous occasions that she leave the United States, go to Guyana, and remain in Guyana, in order to avoid conservatorship. He stated that he knew Mr. Katsaris well, having been a resident of Mendocino County and that PART OF HIS RATIONALE for advising this was the background and understanding he had of Steve Katsaris and Steve Katsaris’s character and personality.
During all of the time that I knew Tim he was an extremely ardent and energetic member of the church. He was very much devoted to its beliefs and its principles into its pastor, Rev. James W. Jones. It is impossible for me to conceive a situation where an attorney has been more involved in or knowledgeable of the total affairs of his client then was Timothy Stoen with the Peoples Temple of the Disciples of Christ, a California Corporation.
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ADDITIONS TO AFFIDAVIT: During all the time that I knew Tim he spent between 20 and 40 hours a week on PT business and on the business of the members under the legal services program.
(NOTE: TOS secretary in Ukiah – Mary something I think, used to do PT work for Tim on his job. I don’t know where she’s at these days, but maybe she could be looked up.)
During the time he was with PT Tim was a very respected member of the Bar. He wrote hundreds of legal memos, many hundreds of letters, copies of which are in our files (I HOPE) and will be presented in our case and he must know beyond the shadow of any doubt that in fact he had, and continues to have confidential information concerning all of the affairs of the PT, and it’s hard to understand how an attorney of his intelligence would permit himself to do the things in violation of the Canons of Ethics and in violation of the Law of the State of California that he has done. The only explanation that I have for his conduct in this regard is that he became so irrationally incensed over the custody matter of J.V. [John Victor] Stoen that he permitted himself to do things that in a more rational frame of mind he never would have done. I think it’s a pity. It’s too bad to see him degenerate in this way.
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Looking over the answer, I want to make a couple of comments. First of all the only defenses he raises are “unclean hands” besides some general denials. Now, I don’t have a law library here, but one thing I remember about the unclean hands doctrine is that the transaction that you raise the defense in has to be the same transaction that the plaintiff is dealing with. That is to say, the defendant has to say the plaintiff acted poorly with respect to the transactions that are the subject of the complaint. Stoen vs. Stoen and the resulting court order in the case with respect to John Stoen is not a subject matter of the complaint and so the unclean hands doctrine does not apply. The only reason John Stoen is included in the complaint is to establish a motive and establish malice, but it is not the same transaction or series of transactions – there is no allegation that Tim represented any member of the church in Stoen v. Stoen, and therefore the first defense of unclean hands should be struck as not being relevant.
The second one “Unclean Hands – Perjury in the Complaint”
I have a hunch that unclean hands doesn’t apply here, because the doctrine applies to the subject matter of the lawsuit, and not the way the lawsuit is framed, or allegedly framed.
The third defense – “Suppression of Evidence.” Same as the second one, and furthermore we haven’t suppressed any evidence in that we can always send Carol [Stahl] back and let her talk.
The fourth defense – Abuse of Judicial Process. Not an unclean hands doctrine.
I think the biggest problem that he’s raised with these things has to do with Charles’ [Charles Garry] reaction to them, and so I want to examine them from that point of view.
The first comment I want to make relates to page 2, lines 22 and those following is that the course never obtained any jurisdiction over Rev. Jim Jones and the fact that the court might have made an error is really irrelevant, I don’t know whether it appears in the court record but I remember somebody told me that when counsel asked for an order directing Jones to return Stoen the judge said, well it seems to me like it’s a waste of time because he isn’t a party, he hasn’t been served, and he’s out of the jurisdiction, but if you want me to do it, I’ll do it. The point that we need to make there is that he’s dealing with that as if it were a contempt but it can’t be because the court has no jurisdiction over him. There is an allegation that plaintiff PT is the alter ego of Jim Jones, but this is something that I don’t know how they’re going to go about proving, that a very large corporation is the alter ego of an individual. Furthermore I don’t know how the hell they can establish that the plaintiff, which is a California corporation is holding anybody in Guyana – since the plaintiff does not exist in Guyana. I think that point ought to be brought home – there is a separate Guyanese corporation under Guyanese law, and it has nothing to do with PT California which at this point simply funds the Guyanese operation. No more, no less. I would also like to point out the conclusions are to be struck from responsive pleadings that relate to a preliminary injunction. Looking at page three, lines 11-13, is nothing but a conclusionary statement – it says nothing specifically that they have done. It can’t in point of fact, because they haven’t done anything.
Second defense: Bottom of page four and five. We should take both positions: Lie detector test. We should say it’s inadmissible, but if admissible on behalf of the defendant, then it’s admissible on behalf of the plaintiff as well, and we should submit our copy of Maria’s lie detector test. And give the court either the choice of accepting both or accepting neither.
As far as the radio business: Whether or not it was a violation of FCC rules has not a thing to do with this lawsuit.
Garry should know that on paragraph d on page 5: What happened was – First of all they weren’t stories. They asked me what happened with Maria & Tim regarding her father. I told them what I had in fact gotten from Maria who was then in Georgetown. They came back with, “that’s not complete enough,” and I came back with, “that’s all we can remember,” several times. I went back to Maria and asked her specific questions, asked her to go over it and see if she could remember anything else. She came back with probably some additional details and I went back and relayed that over the radio. That is what happened – there was no “inconsistency,” just clarification of events that occurred over a year ago.
(SARAH [Harriet Tropp])
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The thing that is of some concern is that the main plaintiff in the suit is PT, and we are mainly concerned with TOS having been chief counsel for PT over the years, now acting– obviously using confidential information against PT. And it’s true that it was decided that Carol Stahl sign the complaint because she is the President of the Corporation, and that’s the reason that it was.
As far as approving any “version” ending up in paragraph six of the complaint, Gene said he didn’t know a goddamn thing about it, because I had no idea what “version” may have been used. Because in fact all I (Gene) know is what I remember of several conversations Tim and I had a couple of conversations that I was with in SF sometime in 1976 in the meeting of April 1977– wherein I remember very, very clearly discussing with him Maria’s case and him giving legal advice concerning it.
Garry should know that this – paragraph e, page 5 – there was no “version.” What was decided that rather than having a lot of people giving Garry info, people who were not at all versed in legal matters, and couldn’t separate relevant from irrelevant info, it would be better not to confuse things, since conducting legal matters at a distance of 5000 miles isn’t the easiest thing in the first place, and isn’t helped by miscommunications and confusions. So we decided that Gene and Sandy would be best to give Garry his info that he needs, along with June, since Jean Brown wasn’t having the best success in sorting out what was and what was not important.
Carol Stahl: Since the principal plaintiff was PT the logical person to verify was Carol Stahl – President of the Corporation. When we’re talking about what Carol Stahl may or may not have been knowledgeable to, let us remember that Carol Stahl was a member of PT from about 1968. One of the oldest members of PT – one of the first in California. Has been in the center of the Temple organization for years and years and years, intimately connected with Tim and certainly enough connected with Temple and familiar with Temple organization and activity to know that although she may not have been personally acquainted with every last thing that was in that complaint, she knew enough about Maria Katsaris and other matters to know that the essence of the complaint and all the basic allegations of the complaint and basic moving facts were true. And she was competent to do that, although she may not have known every single last detail. I want to make a point here on page six – the “because she was expendable to operations in SF and could be shipped to Guyana.” Something in fact was said to the effect that Carol had not seen her daughter in over a year, and her daughter was in fact sick at the time, but more important she hadn’t seen her in a long time, and Carol, as a qualified teacher who’s [whose] contract was up, and who would not be needed in the States right away – it seemed logical for her to come down to see her kid and help in the school. We have a very large school here – fully accredited by Guyana – and we needed more teachers, and she is a highly qualified certificated teacher.
Page 6, paragraph H. The “version” ending up and so and so… It’s a bunch of clear conclusionary stuff that needs to be struck. We said things that we knew to be true – the lie detector test should be attached, probably to Maria’s affidavit, and indicating that Gene, Jones etc. had seen the lie detector test and as far as we were concerned Maria’s story was true and correct. This is very important because it goes to malice. Because having excellent reason to believe her story was correct and it was very easy to believe and understand – from what Maria told us the acts he did he did while he was drunk and we could understand from that he might very well pass a lie detector test because he might not remember his activity… I think this much detail is important because it goes to the state of mind which is part of unclean hands… We believed her story to be true because we had seen a lie detector test indicating that what she was saying was true, and 2) because she told us her dad did these things when he was drunk, and so in fact, we want to lie detector test to go in with our affidavit, controverting Page 6, paragraph H – not only say we believe it to be true but we have very good reasons to believe to be true and that what TOS is saying is false and maliciously false. Furthermore, we’d asked Maria the same questions over a period of better than a year and a half and she’d given us consistent story over this period of time.
Now with respect to this specific “story” on consolidation, if we want to we can point out that the only thing that had to do with specifics
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had to do with trying to pin down the exact dates when some of these conversations took place which is very difficult to do and will be because we didn’t document them at the time, and secondly that the discussions with respect to any attorney had to do with the suggestion that we file a motion to have all of these lawsuits consolidated under the consolidation provisions of the Code of Civil Procedure because Garry was strung out having to defend them all up and down and because we felt that there are common issues of fact and law and it would be cheaper and more convenient to handle them in one suit. The rationale they give for this is all in their head. Bullshit.
If we can get all these things in there especially the lie detector test – it’s going to be difficult for them – and I think that the lie detector test as a result of these allegations will be admissible to prove our motivation (good and valid reason to believe her story to be true before we filed against TOS. We believed it before, but before we went ahead and filed we wanted to be sure so she took a lie detector test, and based on the results of that document we decided to go ahead and file. We felt that although we’d always believed her story to be true, our objective feeling for her as a longtime friend and co-worker wasn’t sufficient and there should be something objective done to substantiate the thing before we actually decided to file. So we went ahead and did it.)
As far as the third defense unclean hands – First of all, all these allegations filed on information and belief are a nullity under California law. Furthermore I think we should point out that nobody has asked for any evidence from her, and they’re not going to be in a position to complain until such time as discovery has been denied and it hasn’t. She can be back in the States in 48 hours with a ticket. We think that the reason all this is thrown in here this to make Charles angry and upset, with us. A divisive tactic.
GENE WANT TO PUT IN HIS AFFIDAVIT THAT HE HAS NO RECOLLECTION OF DISAPPROVING OF HER TESTIFYING UNDER OATH (CAROL) and that he thinks she can testify to anything for which she has first-hand knowledge.
Fourth defense. Medlock and Cobb suits. Gene doesn’t know a fucking thing about the Cobb suit. But he knows a considerable bit about the Medlock case because he discussed the Medlock case with Stoen. We discussed it in our law office meetings on a number of occasions. I consulted with Tim in the Los Angeles church concerning the Medlock case. I know for a fact that he consulted with the Medlocks directly about that, and that he discussed the case with Rev. Jones. I was present in a group discussion of the Medlocks. So I have excellent first-hand knowledge of his participating with the church in that very transaction, as legal counsel for the church. (TOS)
As a matter of fact, this information and belief stuff should be struck. The purposes of the plaintiff, whatever the hell our motivation may be, if in fact we have a good case against Stoen, which we obviously do – is irrelevant. Now all this information and belief stuff, the three defenses and all these allegations – TOS knows as well as we do that information set forth on information and belief in pleadings with respect to an injunction MATTER ARE A NULLITY. Therefore there is only one reason that TOS put all this stuff in here and that is because he wanted it available for media use, putting us in a position where we could not sue for defamation. And the proof of this is that every single time that he has filed a complaint against us in any one of these proceedings it has been immediately followed by articles in newspapers. Big splashy articles in newspapers. Therefore the motivation behind this is pretty obvious as to who would be doing what. We are more inclined to say that the defendant is using this answer in a spurious way because he has included material that is not admissible, he has included material that he knows is a nullity – and obviously they were concluded for the purpose of the lawsuit because they are not receivable by the court and TOS knows that. The purpose of including them was to make it available for publicity purposes.
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THE POINTS AND AUTHORITIES
1. Page 2, pp 1 – unclean hands because aiding and abetting disobedience of California court order. Nothing in complaint or declarations that indicate how that’s being done. A statement to that effect in the Points and Authorities is meaningless.
Perjury in the verified complaint – well, that has yet to be proven. But one legal point is that conduct in the proceedings of litigation is something entirely different in the transaction itself and it is the transaction that we are talking about re: unclean hands. As a matter of fact, it appears to me that the whole answer in the vitriolic and inflammatory way it’s written lends itself more to publicity than it does to a judicially responsive pleading because obviously these things are all subject to motions to strike – which should be made.
Suppression of evidence – again, a ridiculous argument – since they haven’t asked her for anything – how do they know?
Abuse of judicial process –
General nature of complaint – they do have a point. Complaint is not specific enough – needs to be remedied with specific affidavits before it goes to a hearing.
We will come up with things specifically on Medlocks and Cobb. We need to remedy this when Charles gets here. Specific affidavits.
Incidentally, P & A talks about all kinds of crap that isn’t under oath – diversions, threats etc. and even if it were true, I don’t know that it’s at all relevant.
I think we need to add a declaration from Maria, however I would like to point out that she is not the only person who could know what she told Stoen. I can remember some conversations where I was present (Gene)
I don’t know what the problem with producing Maria is – nobody has asked for her. It’s ridiculous.
The allegation that the case is a “sham”. Look, the basic meat of the case is that Stoen acted as our attorney. We can prove that with documents and affidavits beyond a shadow of a doubt. That he had specific knowledge concerning all phases of the corporation including its asset structure etc. The fact of the matter is that the court can take judicial knowledge that he is acting as attorney in a whole bunch of cases which are adverse to the Temple. We’ve got a prima facie case. It has to be dealt with on that basis.
Freedom of speech and right to counsel – Bullshit. No freedom of speech where it’s limited by a license, and there is very clear law to the effect. Traditionally lawyers have had restrictions placed on them, and unless TOS is arguing that the whole code with respect to limitations on attorney confidentiality are violations of first amendment – which is pretty hard to believe.
The declarations of Katsaris, Cobb and Medlock are irrelevant. It really doesn’t make any difference because if he is violating his attorney-client relationship with the church than he is, and he is not entitled to proceed, regardless of their feeling on the matter. As far as Medlocks saying they never discussed the matter with Stoen, that just plain isn’t true.
[Balance of document bracketed by marginal note: “Stoen declaration”]
Cobb Suit – the fact is that for years & years Cobb has been doing all kinds of nasty things to us – badmouthing us etc. and TOS knew the whole background – and so even though TOS maybe alleging that the “unlawful” acts, the particular dates may be subsequent to the time he terminated his relationship is not relevant. Background he had regarding the history of the Cobb-PT relationship, as to the functioning of the church, etc. our extremely relevant to these lawsuits – evidentiary in some instances – perhaps. The information upon which these suits are based (Cobb & Katsaris) and information relating to them those years back, and he was privy to all that.
Medlock is the same thing. With respect to the Medlocks – he participated in it, because the thing started a very long time back, but on page 7, paragraph 14 – we do need specific declarations to remedy the generality of the complaint.
Page 7, line 15 – several of us knew because we were there at the time. Not just Maria. We were all in there in basically a law office situation where that was discussed.
All of these statements where TOS says “if she were called to testify and did so truthfully, she would testify etc.” are subject to a motion to strike. None of it is admissible because it is not a statement of fact. It simply is conjecture about what somebody might say. Not evidentiary. In a hearing on a preliminary injunction based on declarations, the same rules of evidence apply to the declarations that would apply if the person were present in
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court and speaking. This would not be evidentiary if Tim were called in a witness box. Just conjecture. Should be struck.
But just as a factual thing: Maria doesn’t make a claim that she talked to TOS regarding her father & conservatorships after February 1977, on the contrary she says it was the previous fall – Fall of 1976. Also, no one disputes that she was in the US in the Spring of 1977. Nobody even said anything about her being in that meeting in April of 1977, but that she was discussed there – her situation – and he gave advice regarding it.
Paragraph 16 – Re: John. There are several things we should say about that. We ought to get a half a dozen affidavits to the effect that TOS said on numerous occasions that John was Jim’s kid, not his, which he did. Repeatedly. Secondly, the document itself constitutes an admission and as such it most certainly is relevant, and contrary to his position that “everyone knows that the document is false & spurious” that simply is not so. Although we cannot testify that we were in the bedroom we all took TOS’s word for it, and Grace’s as well, in that they constantly told us that John wasn’t his child. As a matter of fact, TOS told Gene that he and his wife had no sexual relationship during the period of John’s conception.
Page 9, paragraph 17: Not relevant to any of the issues in the case. However in respect to TOS’s returning in two to six weeks, that’s hard to imagine in that when he left he didn’t notify anybody that he was leaving nor where he was going – including by the way, John. As a matter of fact, for a period – maybe a few months, the organization had no idea of his whereabouts whatsoever. If that was his intention then he certainly managed to keep it to himself – very conveniently.
Line 14, page 10: Long dissertation regarding mind-programming. Don’t see how this is relevant – is belief or lack of belief is not evidentiary. What is relevant is where he points out in page 10, lines 25-26 what is true motivation for doing all this is – that is, simply, that he wishes to obtain John Victor. That really is his motivation, and the reason for his abusing his relationship as an attorney is because he is so incensed over the John Victor issue.
We ought to also point out that the matter of John is presently being litigated by all the parties in the courts of Guyana, and it’s very difficult to see how on earth he thinks he can influence those proceedings by his activities in the US. So it is pure vindictiveness. An example of his vindictiveness again is that he attached the entire “Inside PT) story – all of which is hearsay and not admissible to the declaration. In addition attached to it is an unsigned, typewritten letter addressed to “Jim” which obviously has no foundation attached to it, because there is no way of attaching a foundation to it – all of which is specifically intended to be as prejudicial as it could possibly be – totally non-evidentiary. It really shows the level of malice this guy has. If we want to use Tim’s methodology, I think if Pat Hallinan were asked to testify, he would testify that Jim wrote all the documents and he simply permitted them to go in with him as attorney of record.
Gene says – he read all these documents, worked with TOS as lawyer for four or five years and recognizes beyond a shadow of a doubt that is all TOS’s style.
Finally, it is true that people have a right to hire an attorney of their choice. The fact remains – why would all these people be so anxious to have Tim if it were not for the fact that he has this tremendous background & experience of PT and a lot of info they can use.