BB-31-b-89
DECLARATION OF CAROL STAHL IN SUPPORT OF COMPLAINT FOR TEMPORARY RESTRAINING ORDER, PRELIMINARY AND PERMANENT INJUNCTIONS, AND DAMAGES
Carol Stahl declares:
- I am the president of plaintiff PEOPLES TEMPLE OF THE DISCIPLES OF CHRIST (hereinafter ” PEOPLES TEMPLE”), a nonprofit corporation.
- I have personal knowledge of the following facts and am competent to testify as to the truth of these facts if called as a witness.
- Defendant TIMOTHY OLIVER STOEN served as legal counsel for PEOPLES TEMPLE from 1970 until approximately July of 1977. He represented plaintiff PEOPLES TEMPLE in various litigation matters, drafted various legal documents for plaintiff PEOPLES TEMPLE, drafted amendments to PEOPLES TEMPLE corporate articles, drafted PEOPLES TEMPLE’s corporate bylaws, wrote numerous letters on behalf of plaintiff PEOPLES TEMPLE, and negotiated numerous transactions, including real estate transactions, on behalf of plaintiff PEOPLES TEMPLE, as its attorney. As legal counsel he routinely gave legal advice to the Border Directors, officers and members of plaintiff PEOPLES TEMPLE, including plaintiffs BROWN and McELVANE.
- On June 5, 1978 I was personally served on behalf of PEOPLES TEMPLE with a complaint for compensatory and punitive damages, filed in the Superior Court of the State of California in and for the County of Mendocino, Civil Action #39911.
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BB-31-b-90
This complaint was filed by defendant STOEN on behalf of Steven Katsaris and against, among others, plaintiff herein PEOPLES TEMPLE. PEOPLES TEMPLE has already been forced to spend considerable time, energy and funds in responding to this suit. I am aware of at least two other suits filed by STOEN against PEOPLES TEMPLE and the other plaintiffs in this action, though none of the plaintiffs herein has yet been served with these complaints. One of these complaints was filed on June 7, 1978 in the Superior Court in and for the County of Los Angeles, Civil Action #24392. This complaint was filed by defendant STOEN on behalf of Wade B. and Mabel M. Medlock against, among others, plaintiffs herein PEOPLES TEMPLE and McELVANE. The other complaint was filed on June 22, 1978 in the Superior Court in and for the City and County of San Francisco, Civil Action #739907. That complaint was filed by STOEN on behalf of James Cobb, Jr. against, among others, plaintiffs herein PEOPLES TEMPLE and BROWN. These complaints may be served upon the plaintiff herein, or any of them, any day. As soon the above-described complaints are served on plaintiffs, or any of them, plaintiffs and each of them will be forced to expend more time, energy and funds responding to these suits.
- In drafting these complaints defendant utilized and revealed confidential information obtained during the course of his attorney-client relationship with plaintiffs and each of them, without the consent of plaintiff PEOPLES TEMPLE or any other plaintiff herein.
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BB-31-b-91
- The filing of each of the suits described in Paragraph 4 supra generated a multitude of news stories adverse to plaintiff PEOPLES TEMPLE and to the other plaintiffs herein. These stories appeared in newspapers throughout California. The adverse publicity generated by these complaints was particularly adverse in the County of Mendocino, the location of one of the actions. This publicity has caused irreparable damage to the reputation of the PEOPLES TEMPLE and of the other plaintiffs herein.
- Defendant solicited the professional employment within the course of which she filed the search described in Paragraph 4. He continues to solicit the employment adverse to the interests of his former clients, PEOPLES TEMPLE and the other plaintiffs herein, for the purpose of harassing and destroying these plaintiffs.
- Defendant STOEN’s solicitation of employment adverse to his former clients, plaintiffs herein, and his violation of the attorney-client privilege of these former clients is a part of a personal vendetta of defendant STOEN against the PEOPLES TEMPLE. He will continue this solicitation and violation of the attorney-client privilege unless and until he is restrained by court order from doing so.
- The activities described in the preceding paragraphs of this Declaration have caused, and will continue to cause if not immediately restrained, irreparable injury to the reputation of plaintiff PEOPLES TEMPLE and the other
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BB-31-b-92
plaintiffs herein. Irreparable energy has also resulted, and will continue to result on a daily basis, from defendant STOEN’s continued disclosure of confidential information concerning plaintiff PEOPLES TEMPLE and the other plaintiffs herein in the course of his solicitation of employment adverse to plaintiffs herein and his prosecution of the students already filed.
I declare under penalty of perjury that the foregoing is true and correct.
This Declaration was executed in San Francisco, California, on July _____, 1978.
/s/ Carol Stahl
Carol Stahl
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[Editor’s note: Pages BB-31-b-93 – b-103 comprise exhibits attached to the Declaration, principally newspaper articles pertaining to the Stoen lawsuits.]
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BB-31-b-104
Verification
I, CAROL STAHL am President of plaintiff PEOPLES TEMPLE, a nonprofit corporation, in the above entitled action.
I have read the foregoing Complaint for Temporary Restraining Order, Preliminary and Permanent Injunctions, and Damages; Memorandum of Points and Authorities; and Declaration in Support of Complaint and know the contents thereof; and the same is true of my own knowledge, except as to the matters which are therein stated upon my information or belief, and asked to those matters I believe it to be true.
I declare under penalty of perjury the foregoing is true and correct. Executed on July _____, 1978 at San Francisco, California.
/s/ Carol Stahl
Carol Stahl