BB-31-a-84
[Marginal note: “Joyce Touchette’s Affidavit will be forwarded later to her. I do not have a spare now. LAL [Lionel A. Luckhoo]””]
- No. 2514 – 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 through her lawful attorney JEFFREY A. HAAS, for a Writ of Habeas Corpus and [illegible word]
– 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 Tuesday the [blank] day of September, 1977, and 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 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 he set aside ex dobito 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 Orders in connection therewith are all irregular, contrary to the Rules observed by the Courts of Guyana and contrary to the 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 dobito justitiae as a nullity, and contrary to Article 5 of the Constitution of Guyana, Chapter 1:01.
(d) A declaration that the proceedings by way of Writ of Habeas Corpus in which Reverend Jim Jones is not even named as a Respondent/Defendant
—–
BB-31-a-85
are bad for want or lack of jurisdiction, of the High Court of the Supreme Court of Guyana.
AND the costs of this application may costs in the nation.
DATED this [blank] day of September, 1977.
The summons was taken out by Mr. Mohammed Ayube Ally McDoom, Solicitor of McDoom & Company, Legal Practitioners, 2 Crool Street, Georgetown, Demerara, for the Applicant herein, resides in 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
—–
[Editor’s note: Balance of document, BB-31-a-86 through BB-31-a-90, illegible.]