BB-31-b-105
PATRICK SARSFIELD HALLINAN
Hallinan & Blum
345 Franklin Street
San Francisco, California 94102
Telephone: (415) 861-1151
Attorney for Defendant
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
PEOPLES TEMPLE OF THE DISCIPLES OF CHRIST, a nonprofit corporation, JEAN BROWN, and JAMES MCELVANE, Plaintiffs,
v.
TIMOTHY OLIVER STOEN, Defendant
No. 740531
DECLARATION BY WADE B. MEDLOCK AND MABEL M. MEDLOCK OPPOSING APPLICATION FOR PRELIMINARY INJUNCTION
We, Wade B. Medlock and Mabel M. Medlock, husband and wife, hereby declare as follows:
1. We are the plaintiffs in a lawsuit entitled WADE B. MEDLOCK and MABEL M. MEDLOCK vs. JAMES WARREN JONES, PEOPLES TEMPLE, JAMES MCELVANE, et al., filed on June 7, 1978 in the Superior Court for the County of Los Angeles, Civil Case No. C243292. A copy of the complaint is attached and made a part hereof. Our attorney is Timothy Oliver Stoen.
2. This declaration is made in opposition to plaintiff’s application for a preliminary injunction. We are requesting that
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Timothy Oliver Stoen be allowed to remain as our attorney and help us get back the money stolen from us by PEOPLES TEMPLE.
3. I, Wade B. Medlock, am 71 years old. I, Mabel M. Medlock, am 67 years old. Tor 33 years we worked together in our own maintenance business in Los Angeles to acquire equity into pieces of property as security for our senior years. In February 1977, our pastor, Jim Jones, called us into the “council room” of the PEOPLES TEMPLE church in Los Angeles and showed us some papers already filled out. We knew that they were for the sale of our properties, and we did not want to sign. When we hesitated, Jim Jones said to us personally, in front of a number of other people in the room, that if we didn’t sign those papers immediately we would “die”. We took this as a serious threat we would be killed, and we therefore signed against our will. When the escrow closed in August 1977, we were given $7000.00 and PEOPLES TEMPLE took more than $48,000.00. (Both properties have been sold at prices far below fair market value.) We were heartsick but were afraid for our lives to complain to anyone. Jim Jones then started putting a lot of pressure on us to go to Guyana, where a number of our relatives are. But we did not want to live in in any jungle, so we kept refusing.
4. Members of PEOPLES TEMPLE kept coming to us and asking us why we did not go to Guyana. In January 1978, an associate PEOPLES TEMPLE minister, Hugh Fortsyn [Hue Fortson], threatened both of us with the same fate (murder) as had happened to Christopher Lewis. On Easter Sunday of this year, JAMES McELVANE threatened that we
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had better watch out because “what happened to Chris could happen to you.”
5. On April 25, 1978, ex-members of PEOPLES TEMPLE held a meeting of “Concerned Relatives” at a Baptist Church in Los Angeles. At the meeting we told the people what PEOPLES TEMPLE and Jim Jones had done to us. Afterwards Steve Katsaris said we should sue the church, and he told us to talk to Tim Stoen. Tim Stoen said to call in the next day, which we did. On April 26 we took the papers we had gotten from the escrow company to Tim Stoen to look at. He said we have been “extorted” and that we had a good case against PEOPLES TEMPLE but that they would probably try to sell all their property before we got a judgment. But since we don’t have enough to live on, we are not going to give up.
6. We asked Tim Stoen not to file a lawsuit until we could move to safer living quarters. We were in constant fear that PEOPLES TEMPLE would send someone into our apartment at night and stab us. When we moved in May, we told Tim Stoen to file the lawsuit, which he did. Since then we have not received any more threats from PEOPLES TEMPLE.
7. Tim Stoen never talked with us about selling our property or turning it over to PEOPLES TEMPLE. He very seldom came to Los Angeles. He had nothing to do with our transferring it to the church. We did not even see him from September 1976 until the meeting in April 1978.
8. Tim Stoen never asked us to sue PEOPLES TEMPLE or JAMES
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McELVANE. We asked him to do it for us. We are very glad he did. We do not want him taken off our case.
9. We authorize Tim Stoen to disclose all of the information we have given him regarding our lawsuit.
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VERIFICATION
I, the undersigned, say:
I am a declarant in this action; the above document is true of my own knowledge, except as to the matters that are stated in it on my information and belief, as [and] as to those matters, I believe them to be true.
Executed on July 24, 1978, at Los Angeles, California.
I declare under penalty of perjury that the above is true and correct.
s/s WADE B. MEDLOCK
WADE B. MEDLOCK
/s/ MABEL M. MEDLOCK
MABEL M. MEDLOCK