BB-31-b-69
Charles R. Garry
Garry, Dreyfus, McTernan, Brotsky, Herndon, & Pesonen, Inc.
1256 Market Street at Civic Center
San Francisco, California 94102
Tel: 864-3131
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.
[740531]
ORDER TO SHOW CAUSE AND TEMPORARY RESTRAINING ORDER
On reading the Complaint, supporting Declarations, and Points and Authorities on file in this action, and it appearing from these that this is a proper case for issuance of an order to show cause and a temporary restraining order, and then unless a temporary restraining order issues, plaintiffs will suffer irreparable injury before the matter can be heard on notice,
IT IS ORDERED that defendant, TIMOTHY OLIVER STOEN, appear before this Court in the courtroom of Department
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No. _____, at _____ on _____ then and there to show cause why a preliminary injunction should not be issued enjoining defendant from:
- Soliciting professional employment from ex-members of PEOPLES TEMPLE, relatives of members of PEOPLES TEMPLE, or from any other persons for the purpose of generating suits against plaintiffs or any of them or against any officers, directors or members of plaintiff PEOPLES TEMPLE;
- Accepting professional employment adverse to his former client PEOPLES TEMPLE or to any directors, officers or members of PEOPLES TEMPLE, including all plaintiffs herein, during the course of which employment he will have or might have occasion to use any confidential information obtained in the course of the attorney-client relationship between defendant and PEOPLES TEMPLE;
- Disclosing under any circumstances any confidential information obtained during the course of the attorney-client relationship between defendant and PEOPLES TEMPLE, and between defendant and any officers, directors or members of PEOPLES TEMPLE, including all plaintiffs herein, unless such disclosure is with the written consent of the PEOPLES TEMPLE:
- Prosecuting in the complaint already filed which was filed in violation of the attorney-client privilege or the prohibition against accepting employment adverse to a former client, during the course of which defendant will have, or might have, occasion to use in the confidential information obtained
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BB-31-b-71
during the course of the attorney-client relationship between defendant and PEOPLES TEMPLE.
IT IS FURTHER ORDERED that pending the hearing on the order to show cause, defendant, his agents, officers, employees, and representatives, and all persons acting in concert or participating with him, are hereby enjoined from:
- Soliciting professional employment from ex-members of PEOPLES TEMPLE, relatives of members of PEOPLES TEMPLE, or from any other persons for the purpose of generating suits against plaintiffs or any of them or against any officers, directors or members of plaintiff PEOPLES TEMPLE;
- Accepting professional employment adverse to his former clients PEOPLES TEMPLE or to any directors, officers or members of PEOPLES TEMPLE, including all plaintiffs herein, during the course of which employment he will or might have occasion to use any confidential information obtained in the course of the attorney-client relationship between defendant and PEOPLES TEMPLE;
- Disclosing under any circumstances any confidential information obtained during the course of the attorney-client relationship between defendant and PEOPLES TEMPLE, and between defendant and any officers, directors or members of PEOPLES TEMPLE, including all plaintiffs herein, unless such disclosure is with the written consent of the PEOPLES TEMPLE;
- Prosecuting any complaint already filed which was filed in violation of the attorney-client privilege or the
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BB-31-b-71
prohibition against accepting employment adverse to a former client, during the course of which defendant will have, or might have, occasion to use any confidential information obtained during the course of the attorney-client relationship between defendant and PEOPLES TEMPLE.
IT IS FURTHER ORDERED that a copy of the Complaint, Declarations, and Points and Authorities, together with a copy of this Order to Show Cause and Temporary Restraining Order, be served on defendant not later than _____.
Dated: _____
_____
JUDGE OF THE SUPERIOR COURT