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[Letterhead of Patrick Sarsfield Hallinan]
August 9, 1978
Charles R. Garry, Esquire
Garry, Dreyfus, McTernan, Brotsky,
Herndon & Pesonen, Inc.
1256 Market Street at Civic Center
San Francisco, California 94102
Re: Peoples Temple, et al. vs. Stoen
No. 740531
Dear Mr. Garry:
The Superior Court has set a hearing on your request for a preliminary injunction in the above-entitled matter for Thursday, the 7th of September, 1978, at 9:30 a.m.
Pursuant to Section 1987(b) and (c) of the Code of Civil Procedure, we request that you present Jean F. Brown, James McElvane, Carol Stahl, and the Reverend Jim Jones, an officer, director or managing agent of Plaintiff herein and the person for whose immediate benefit said action is brought, and a necessary witness to the matters alleged in Plaintiff’s moving papers. We also require production of any books, records, papers, files or the like in the possession of the Plaintiffs, or any of them, or in the possession of the Reverend Jim Jones, which establish, support, confirm or contradict any of the affirmative allegations contained in Plaintiff’s moving papers. Said appearances and productions to be on the date heretofore set for hearing on the preliminary injunction before the Law and Motion Department thereof, the Honorable Ira Brown, Judge presiding, for the purpose of the examination of said persons and documents.
Please advise me as to your intentions in this matter at your earliest possible convenience.
Sincerely yours,
/s/ Patrick Sarsfield Hallinan
Patrick Sarsfield Hallinan
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[Letterhead of Patrick Sarsfield Hallinan]
August 9, 1978
Charles R. Garry, Esquire
Garry, Dreyfus, McTernan, Brotsky,
Herndon & Pesonen, Inc.
1256 Market Street at Civic Center
San Francisco, California 94102
Dear Charlie:
Pursuant to my discussions with Dave Pesonen, I am sending you a file-marked front sheet of the Answer to the Complaint in Peoples Temple vs. Stoen. All of the remainder of the materials are identical to those I delivered to David in Court on the day of filing.
Best regards,
/s/ Patrick Sarsfield Hallinan
Patrick Sarsfield Hallinan
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[Editor’s note: This is the first page of a document which appears in its entirety at https://jonestown.sdsu.edu/?page_id=126148.]
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[Editor’s note: This document also appears as x-4-g-39 - 40 at https://jonestown.sdsu.edu/?page_id=130304. It also appears at NN-4-R1 – R2 in this pdf.]
[Letterhead of Law Offices of Charles R. Garry, San Francisco]
May 4, 1978
Police Chief Charles Gaines [Gain]
San Francisco Police Department
Hall of Justice
850 Bryant Street
San Francisco, CA,
Re.: People’s Temple
Dear Chief Gaines:
Last night, People’s Temple at 1859 Geary held a free concert for its members and invited the public. That concert ran from approximately 7:30 P.M. to 9:00 P.M.
An attorney associated with this office and in attendance last night observed the following events along with several members of the People’s Temple:
1) About 9:30 P.M. members of the People’s Temple reported that a uniformed police officer in an unmarked car was parked in the parking lot next to the People’s Temple at the corner of Steiners and Geary. That car was a blue two-door Honda, California license No. 998-RNB.
2) The attorney from this office along with both members of the People’s Temple approached the officer and asked why he was spying and eavesdropping on the People’s Temple. The officer denied any such actions and would not explain his presence. The officer’s badge number is No. 2583.
3) One of the members of the People’s Temple then took four photos of the officer.
4) The officer then left his car and approached the three men and stated he was on a stake-out for a 211. That there had been robberies of several “Fish and Chip” restaurants that night, and that this was the last one in the city, and that he was waiting for the robber.
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Police Chief Charles Gaines
Page Two
May 4, 1978
5) It was also reported that another man who talked to this officer was seen next to the People’s Temple outer wall and appeared to be eavesdropping with some sort of equipment.
This whole matter appears to be another example of Government harassment of the People’s Temple.
Very truly yours,
/s/ Charles R. Garry
Charles R. Garry
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[Letterhead of San Francisco attorney Charles Garry]
September 13, 1977
Owen and Nancie Spann
27 Hillcrest Road
Tiburon, California 94920
Dear Owen and Nancie,
My last night on earth, before becoming a member of the SPACE COLONY would be spent in a friendly and comfortable place. I would like to be able to be comfortable in a robe and slippers, good music in the background, soft lights, a roaring fire in the fireplace, and surrounded by those I love and the sounds and smells and things that most turn me on.
I would like my meal to begin with scotch on the rocks, the best scotch on the rocks – 30 year old Chevis Regal. The meal would consist of steak tender enough to melt in your mount, broiled to perfection, full of flavor. I would like sweet red peppers, also broiled and pealed. Fresh asparagus with melted butter, sweet corn – fresh of course – again with melted butter, pizza bread, Armenian cracker bread, a salad made with romaine lettuce, tomatoes, red onions, tart apples, crisp cucumbers, and a sweet and sour vinegar and oil dressing. I would also like to have some, steak tartar – but done the way I like it, recipe enclosed. The dessert would be a hot fudge sundae or chocolate ice cream.
I would spend this evening with those I truly love and admire, my assistant Pat Richartz, Huey Newton, Gwen Newton, Rev. Jim Jones, his wife Marcelyn [Marceline] Jones, Carleton Goodlet [Goodlett], Terry Buford, Dennis Banks, Don Freed, Bill Walton and Susan, Jack and Micki Scott, Johnny Spain (free at last from prison), George Jackson, Julius and Ethel Rosenberg, Sacco and Venzetti, Morton Sobell, Bob Wells, Dr. W. E. B. DuBois, Victor Hugo, Arthur Turco. Then there are many people I would like to stop
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by – my partners and their wives, friends and colleagues from all over the country, the list would be endless. I hope this is what you wanted Owen and Nancie. I have spent hours on it. Oh yes, some of the children I know could even stop by if they promise not to stay more than a few minutes. You know, I am a firm believer in disliking both dogs and children – so I can’t be all bad.
As ever,
Charles R. Garry
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STEAK TARTAR
1 lb. top serloin steak, fat removed, ground three times
2 cup fine cracked wheat salt and pepper to taste
3 cups water
Knead together the steak, cracked wheat, salt and pepper gradually adding the water for twenty (20) minutes. Place the meat on a platter, spreading it out to cover platter.
Next, finely chop,
4 tart apples
5 red onions
1 bunch fresh parsley
2 green peppers
Toss together and spread over the meat on the platter.
Serve with Armenian cracker bread.
This serves two people double the ingredients for added people.
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[Letterhead of San Francisco attorney Charles Garry]
July 29, 1978
Mr. Skip Roberts
Director of Criminal Investigation
c/o Police Headquarters
Eve Leary
Kingston, Georgetown
Guyana, South America
Dear Mr. Roberts:
I am attorney for Peoples Temple of the Disciples of Christ in the United States. My client has informed me that your office is conducting an investigation into the complaints filed regarding Deborah Layton aka Deborah Blakey.
I would appreciate your sharing with me the current status of the case, in order that I might discuss its ramifications with my clients here. You may check with Maria Katsaris, Tim Carter or Debbie Touchette at the Peoples Temple headquarters in Georgetown, phone #71924, for verification. Thank you for any assistance you might provide.
Sincerely,
/s/ Charles R. Garry
Charles R. Garry
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[Letterhead of San Francisco attorney Charles Garry]
January 30, 1978
PERSONAL AND CONFIDENTIAL:
Honorable Griffin B. Bell
Attorney General of: the United States
U. S. Department of Justice
Washington, D.C. 20535
Dear Sir:
This office represents a former FBI agent with many years of service, who believes that for years the Bureau has violated every form of due process of law in its endeavors. If proper assurances of sincere investigation are forthcoming, he is willing through his attorney to cooperate, but not until then.
The attached exhibit “A” from my client should enable you to see that my client knows what he is talking about.
As you can see, the corruption is continuing even under the directorship of Clarence Kelley. As my client points out, Mr. Kelley and his subordinates have given false testimony before the U.S. Senate. He points out that the matters he has listed are relatively minor compared to the information not yet revealed and still within the statute of limitations.
I will be available to meet with you and you alone on this matter.
Very truly yours,
/s/ Charles R. Garry
Charles R. Garry
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EXHIBIT “A”
Those activities of corruption and abuse of authority which are within the five-year statute of limitations are listed below so that the Attorney General can investigate and police the FBI and the Justice Department:
1. In April, 1973, an-FBI informant stole or, in FBI jargon, “borrowed” the entire lot of membership applications of the American Indian Movement (AIM) in Los Angeles.
2. In August, 1973, an FBI informant “borrowed” various lists from the offices of the National Socialist White Peoples Party. It was done once before by this same informant in January, 1972; however, 1972 is not within the statute of limitations.
3. When GAO conducted a survey in 1974 of cases opened in the Los Angeles office, the FBI furnished false information to GAO in an attempt to cover up the fact that FBI informants had stolen records from various groups in the Los Angeles area. FBI officials in Los Angeles deliberately furnished false information to GAO as to the reason cases were opened on lists of names stolen from the NSWPP and the reason cases were closed on AIM members.
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4. In December, 1973, the Los Angeles office was involved in investigation of a kidnapping in Palm Springs, California, which had actually begun in the summer of 1973. The victim was never found. The victim’s father, who allegedly had organized crime connections in Detroit, sent numerous gifts to the employees of the Los Angeles office who participated in the investigation. The stenos and clerical employees, as well as special agents, received clock-radios. Assistant Director in Charge, William A. Sullivan, Special Agent in Charge, Arnold C. Larson, Special Agent in Charge, Elmer Linberg, Supervisor, Leo LaRue, Supervisor, Leslie Norregard, and Supervisor, Jeb Lehew received wrist watches, valued at $400 each.
5. In April, 1974, an agent in the Los Angeles office, pocketed $600 which was to have been an informant payment, but the informant left town because the FBI wanted him to testify against 3 officers involved in organized crime. The informant was- named as an unindicted co-conspirator and he departed Los Angeles never to be contacted again by the FBI. This informant was controlled by Special Agent, Donald K. Crabtree, now a supervisor. The file does not contain the FD-209 (contact form) showing the $600 payment on April 26, 1974, the date the informant was told he would be named an unindicted co-conspirator.
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6. In 1975-76, an FBI agent assigned to the San Diego office was arrested for smuggling narcotics into the U.S. from Mexico. The FBI and other agencies covered up the arrest and allowed the agent to resign. Mr. Kelley should have had the agent prosecuted and exposed for what he was.
7. On August 26, 1975, it was announced in an all agents conference that 63% of all Bureau cars are being taken home at night by Special Agents. This is in direct violation of Title 31, United States Code, Section 638a(c) (2) – Use of Government Vehicles for Official Purposes. It was announced at this same conference that an agent’s daughter had had an accident while driving a Bureau car. No mention was made as to prosecutive action taken against the agent or whether he was even disciplined.
8. On August 26, 1975, it was also announced at the conference that the Richmond FBI office covered up a matter involving illegal bugging by the local police.
9. In September, 1976, some police officers attending the FBI National Academy became involved in a drunken rampage in the sleeping quarters to which they were assigned at Quantico, and they raped a fellow police officer,
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committing sodomy. This matter was covered up by top level officials at Quantico and the Bureau.
10. On October 1, 1976, Assistant to the Director Deputy Associate Director James B. Adams, submitted a sworn affidavit to the United States District Court, Southern District of New York in the case of the Socialist Workers Party, et al., Plaintiff, v. Attorney General, et al., Defendants. 73 Civ.3160 (TPG). Mr. Adams’ affidavit contains numerous statements of untruth, it is a gross misrepresentation of the facts and is an insult to Honorable Thomas P. Griesa, D.J.
11. On October 20, 1976, a clerical employee of the Los Angeles FBI office was making the rounds of the office to enroll participants in the weekend football pool. This employee had won the previous week and was not required to arrange for the next pool of $100. These pools are all operated on government time and on government property.
12. In March, 1977, the Los Angeles office had a continuing pool on the NCAA basketball playoffs. A special form was made up by the FBI gambling squad (a squad formed to investigate organized gambling in the Los Angeles area), with the various odds taken from the wire taps on the known gamblers.
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[Letterhead of San Francisco attorney Charles Garry]
June 9, 1978
Santa Rosa Press Democrat
427 Mendocino Avenue
Santa Rosa, CA. 95404
Re.: Retraction—– “Reporter’s trek to Jonestown turns into nightmare”
Management:
On behalf of my clients, the People’s Temple, demand is hereby made for you to retract the innuendoes and the assertions therein made that the People’s Temple either directly or indirectly had anything to do with the allegations contained in your Thursday, June 8, 1978 full page dissertation page 13C.
It is our understanding that Kathy Hunter went to Guyana under your direct assignment and control to do a particular type of “hatchet job”.
My clients herewith demand that you publish fully the enclosed open letter to the media and the community without any changes in the entire format.
Very truly yours,
/s/ Charles R. Garry
Charles R. Garry
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[Editor’s note: This document appears at https://jonestown.sdsu.edu/?page_id=94307.]
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[Editor’s note: This document also appears as x-4-g-9 at https://jonestown.sdsu.edu/?page_id=130304.]
[Letterhead of Law Offices of Charles Garry]
October 3, 1977
United States Customs Service
District Office
555 Battery Street
San Francisco, CA.
Attention: District Director
Re.: Peoples Temple Shipment to Peoples Temple Agricultural Mission, Georgetown, Guyana
Dear District Director:
On August 29, 1977, my client had a large shipment to Georgetown, Guyana, South America. The shipment was a freight forwarded to SOPAC Transport Corporation in Miami, Florida.
On information directed to us stated that seven customs men held up the cargo and examined the contents of some of the shipments.
I have been asked by my clients to inquire upon what information was this cargo examined and what prompted it. We are very much interested in determining who and by whom we are being maligned. I am sure that your service would not take the time of seven men unless some form of prior information was forwarded to you. I think since the matter concerns my clients that we should be privy to that.
My clients wish to inform you and to the service generally and specifically that they do not in any way intend to, nor have they in the past ever violated any of the customs laws of the United States or for that matter of any country. Please let me hear from you regarding this matter that is disturbing to my clients.
Very truly yours,
/s/Charles R. Garry
Charles R. Garry
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[Letterhead of Hallinan and Blum]
August 9, 1978
Charles R. Garry, Esquire
Garry, Dreyfus, McTernan, Brotsky, Herndon & Pesonen, Inc,
1256 Market Street at Civic Center
San Francisco, California 94102
Re: Peoples Temple, et al. vs. Stoen
No. 740531
Dear Mr. Garry:
The Superior Court has set a hearing on your request for a preliminary injunction in the above-entitled matter for Thursday, the 7th of September, 1978, at 9:30 a.m.
Pursuant to Section 1987(b) and (c) of the Code of Civil Procedure, we request that you present Jean F. Brown, James McElvane, Carol Stahl, and the Reverend Jim Jones, an officer, director or managing agent of Plaintiff herein and the person for whose immediate benefit said action is brought, and a necessary witness to the matters alleged in Plaintiff’s moving papers. We also require production of any books, records papers, files or the like in the possession of the Plaintiffs, or any of them, or in the possession of the Reverend Jim Jones, which establish, support, confirm or contradict any of the affirmative allegations contained in Plaintiff’s moving papers. Said appearances and productions to be on the date heretofore set for hearing on the preliminary injunction before the Law and Motion Department thereof, the Honorable Ira Brown, Judge presiding, for the purpose of the examination of said persons and documents.
Please advise me as to your intentions in this matter at your earliest possible convenience.
Sincerely yours
/s/ Patrick Sarsfield Hallinan
Patrick Sarsfield Hallinan
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[Letterhead of Hallinan and Blum]
August 9, 1978
Charles R. Garry, Esquire
Garry, Dreyfus, McTernan, Brotsky, Herndon & Pesonen, Inc,
1256 Market Street at Civic Center
San Francisco, California 94102
Dear Charlie;
Pursuant to my discussions with Dave Pesonen, I am sending you a file-marked front sheet of the Answer to the Complaint in Peoples Temple vs. Stoen. All of the remainder of the materials are identical to those I delivered to David in Court on the day of filing.
Best regards,
/s/ Patrick Sarsfield Hallinan
Patrick Sarsfield Hallinan
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[Letterhead of Peoples Temple attorney Charles Garry]
June 17, 1978
Editor
San Francisco Chronicle
5th and Mission Streets
San Francisco CA 94119
Dear Editor;
This letter is written in the interest of fair play. The latest salvo against the Peoples Temple that your paper grabbed onto is the allegation made by Deborah Layton (The Chronicle, June 15). Her mother, Lisa, and her brother, Larry, both denounced her and stated the reasons why. No reference was made to their charges in your paper.
On May 28 at a press conference when your reporter was present, Rev. John Moore and his wife, who had just returned from Jonestown, Guyana, said as follows:
“I’m John Moore. I’m pastor of the First United Methodist Church in Reno, Nevada. We have two daughters who are members of the Temple, obviously my wife and I are not members of the Temple. One, the older girl’s a teacher, and the younger one is a nurse. The two words that come to my mind, immediately as I was there and as I tried to reflect upon my experiences were ‘impressive’ and ‘amazing.’ It almost boggles my mind to see that great clearing and to understand how so much could have been done in the relatively short period of time. I think about a thousand acres, 800 acres have been cleared, and it’s in the midst of a jungle, and that’s part of what’s impressive, and all except a part of the road that’s not been finally cleared, has been planted with various crops.
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“I had a feeling of freedom. Neither in Georgetown, where there were about 25 or 30 people living, coming and going, all the time, with total freedom, nor at the project itself, did we – did I have – I’ll let my wife speak for herself – did I have any feeling that anybody was being restrained or coerced or intimidated in any way. What did impress me was that people who were living in Georgetown, in the house there, were all eagerly waiting for the time when they could return to Jonestown, and the project itself. One of the great things, I think, is the opportunity for some of the younger people, particularly, to be learning skills when that opportunity is not present here.
“They have probably 35 preschoolers. I don’t know how many they have in school; they have newborn babies, several babies have been born there. They have a daycare nursery for parents to work, and there are those who are caring for them; and then they have the older people. That’s really a part of the beauty of it, we felt.
“The school is accredited by the government of Guyana, that they’ve had people from the Department of Agriculture and their agricultural stations there working with the people at the project. And certainly their supporting of the health center, there’s no question in my mind but that the health center is the best facility in that whole region in Guyana. There is a government, I think, nurse practitioner, in Port Kaituma a few miles away, but that simply does not have either the personnel, skills nor the equipment that they have. The health services are provided for the AmerIndians or people who live in the community as well as the members of the project itself.”
Mrs. Barbara Moore said the following:
“My impressions are, having just experienced our visit there, that this is a beautiful, heroic, creative project! It is absolutely miraculous. There are excellent medical services, excellent educational services, and… it’s a community of caring and sharing with an added dimension, in this dimension I would say, is love. If you want to use that term; in a sense it reminds me of… a New Testament community, in the purest sense of the word, in the love and concern for all, that we observed. And with
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complete freedom for creativity; those who want to farm, are farming; those who want to teach, teach; those who like to cook, cook; they have an excellent nutritionist who was working scientifically all the time to discover new uses for the indigenous plants and growths there, and is in contact with the Guyanese experts to discover new and useful uses for these various crops, there. That was very impressive to me. It was most impressive to see the elderly people, the older folks, who had their neat little yards, the little white picket-type fences, and there opportunity to take classes if they wished to, or to garden, or to just sit. They also have a lovely library of over 8000 volumes, from poetry to ‘how-to-do-it’…
“It’s a complete city and one thing they encourage is the nuclear family. You can choose to have your own home, or if you are a single person, you may live in a dormitory, which ever you prefer. They have a lovely nursery for infants; they have a nursery for toddlers, and of course a fine educational set up.”
It is to be noted that not one word of the foregoing was reported. Rev. and Mrs. Moore spent in excess of two weeks at the jungle mission. Isn’t it about time that the voices of the 1400 people who are in Guyana pioneering a new way of life received equal coverage?
Very truly yours,
/s/ Charles R. Garry
Charles R. Garry
Attorney for Peoples Temple
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February 16, 1978
Charles R. Garry
Attorney at Law
1256 Market Street
San Francisco, Ca. 94102
Dear Mr. Garry:
Per our telephone conversation on December 18, 1977. If you recall, Ms. Jane Mutchmann [Mutschmann] of People’s Temple Church referred me to you as the church counselor. I have made several attempts to resolve this matter by other means, unfortunately it is necessary for me to get conformation from the church.
I started attending meetings at the People’s Temple Church in 1970, at which time generous contributions were given. When I say generous, I am only making reference to my income level. In 1972 I started [to] pay “commitment” in the sum of One Hundred-Fifty Dollars ($150.00) per month. This amount of course was in addition to special pledges, and regular meeting contributions. Beginning 1973 through 1974, I paid the “commitment” sum of Two Hundred Ten Dollars ($210.00) per month. Beginning 1975 the entire congregation was requested to pay commitments in cash. We followed these instructions without question, and not thinking about the consequences of Income Taxes and/or audits. Later in 1975, I became a part of the communal living structure. As a part of this structure, I was required to donate my entire income, of Three Hundred-Thirty Five Dollars/Forty Three Cents ($335.43) by-weekly for over a period of one year.
I feel it is necessary to at least outline a few of the types of contributions I made during my membership with the church:
one $2,300 Ring – Gold Wedding Band with an $1,800 Jade stone with four 12 point Diamonds; A White Gold Band with one caret cut Diamond stone (first wedding band); A White Gold One half caret Stone surrounded with a horse shoe of six cut diamond points, cost approximately $650.00 in 1960.
Fur Coats: Full length Ranch Mink Coat; Full length Grey squirrel coat; Full length Brown Beaver coat; A full length Black Baby Seal coat trimmed with Black .Fox and a designers Full length Power Blue and White Australian’Lamb coat. A fur collection estimated cash value of $15,000.
Three Thousand ($3,000) Dollars Savings deposited at Fireside Thrift Savings and Loan and the Bank of Tokyo.
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A coin Collection estimation unknown, but cash value of Four Hundred Dollars in Buffalo nickles, mecury dimes, silver dimes, quarters, half dollars, whole dollars and one. One ten dollars Gold certificate, in addition Six ($6,000) Thousand Dollars in pledges over a period of four-five years.
By no means can I ever obtain again the family heirlooms, coin collections, jewels, furs, energy and many sacrafices which I made in good faith.
I have estimated the approximate figure of Forty-Fifty Thousand Dollars of personal donations and monies accumulated over the greater part of my life. I am a single black mother which makes it all the more difficult for the Internal Revenue to acknowledge such sacraficial donations.
The sum of $8,542.58 can be verified through my previous payroll system, because I did maintain my check stubs. But this process is extremely time consuming, therefore, your clients cooperation in resolving this matter will be greatly appreciated.
I am further requesting as a suggestion from the Internal Revenue and my previous employer who firmly indicate that a receipt for all donations should have been issued by your client, such a receipt and/or written statement verifying the moderest sum of Fifteen Thousand ($15,000) Dollars. Again, this in my opinion is a reasonable request. And I look forward to hearing from you in the very near future.
Please find copies of my personal checks verifying large contributions.
Yours very truly,
Kay Henderson
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[Photocopies of four personal checks signed by Kay Henderson]
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[Editor’s note: This document appears above at NN-4-A1 – A2]