Editor’s note: This page consists of statements by Temple attorney Eugene Chaikin and affidavits filed by several Jonestown residents outlining the Temple’s statements of facts and strategy in fighting the lawsuit brought by Wade and Mabel Medlock. The lawsuit was one of three filed by Timothy O. Stoen in 1977.
FF-2-2A
Handwritten summary by Eugene Chaikin
Outline of the Medlock Transaction
Wade and Mabel Medlock had come to church services in 1971 and 1972, when meetings were held in the Embassy Ballroom in Los Angeles, monthly. In the winter of 1972, when the church acquired a church building in Los Angeles, they became regular members.
During counseling sessions beginning in 1973 and early 1975, it became evident they were not a happy couple. Wade Medlock repeatedly told many members of the congregation he wanted to sell their two properties, give his share to the church, and divorce his wife, who he claimed was [illegible word] him. [Marginal note: “Note stock donation”]
He talked to Tim about this in 1975 & consistent with church policy, Tim advised him to try and get along with his wife. Nevertheless Wade continued to complain about his wife and further complained that the church was not doing enough to assist him in making the gift. The matter was brought to a head in mid-summer when Wade talked to Archie Ijames, long-time member and associate pastor. Archie brought it to a government meeting one Saturday night in L.A. Present among others were Kay Nelson, Tim Stoen, Tish Leroy, Jim Jones, Clara Johnson (niece of the Medlocks). The matter was discussed and Tim advised on what would be legal and proper under the circumstances. It was decided that both would be asked to sign a gift deed, but on the verbal condition that
—–
FF-2-2B
[notation at head of page: “Outline that Tim Stoen had legal advice in the Medlock assignment.”]
they would continue to reside in and [illegible word] the properties, [illegible word] them and make payments on loans and taxes until such time as the church should need the funds for the development of the Guyana mission project. [illegible two-line insert] Some of those selected to speak to the Medlocks about the matter were: Clara Johnson; Tim Stoen; Kay Nelson; Archie Ijames; and Tish Leroy.
The next day the Medlocks were asked to speak to the group, and were asked to sign deed forms. These forms were presented and the signing supervised by Tim Stoen.
After the signing, that evening Stoen gave Kay Nelson a file containing the blank deed forms each signed by Wade and Mabel Medlock. The file was marked “Medlock Real Estate” or similar words and [illegible word] stapled on the right hand side yellow lined foolscap with about a half-page of handwritten notes in Tim’s handwriting. It also contained other papers [illegible word] the legal descriptions of the two properties. Tim asked Kay to be sure that the deeds were not recorded because of the commitments made to the Medlocks requesting their use.
Things were fairly quiet till the fall of 1976 when it was decided that the church would need the funds for the Guyana mission project.
—–
FF-2-2C
Kay then went to the Medlocks and asked them to sign a listing agreement, which they did. However, each time she wanted to show the properties Mabel would make excuses. She informed Rev. Jim Jones of this. He consulted Stoen who advised him on the best course to take, and [inserted word illegible] that would not make the transaction vulnerable to rescission. The next evening, at a meeting of many key members of the church at which all of the previously-mentioned persons, including Stoen, were present, the transaction was again discussed. Several days later the Medlocks signed another listing agreement (the first had apparently expired) and thereafter cooperated fully in the sale of the properties. The church spent a great deal of money and several months in the repair of the properties to ready them for sale. The escrow instructions were originally made out so that the sale proceeds (net of repair costs) were to be delivered 1/2 to P.T. (representing Wade’s share) and 1/2 to Mabel Medlock, representing her share. Subsequently Mabel signed separate instructions authorizing the delivery of her share of the proceeds to P.T. The deeds that TOS had signed was never used.
Several months later the Medlocks protested to Kay that they wanted their money back. As the [illegible word] Wade told Kay: “The first person who talked to me from the church about signing my property was that [illegible] attorney who left the church…
—–
FF-2-2D
you know, Tim Stoen.”
—–
FF-2-3A
Affidavit of Kay Nelson
[Several lines inserted at top of page: “Working with all of these activities, I was constantly in contact with Timothy O. Stoen. I was directed by him and the Board that he should approve all transactions, so I consulted with him very frequently. He often corrected or drafted the documents I used.”]
By profession I am a Real Estate Broker, licensed by the DRE and worked as such in in L.A county for ____ years, from ___ to ___.
I have been an active member of P.T since____ and from and after ____(1972). I participated in organizational business and committee meetings. I was often involved in transactions for the purchase and sale of Real Estate, and also in [illegible] sales and other money raising [illegible]. I was also a church counselor [illegible line].
During 1973, 1974, and 1975 the congregation of P.T. numbered over 10,000 members of various [illegible word] degrees on interest and activity. From time to time the church would receive donations of real property which I would generally cause to be renovated and sold. It was in this context that I first became familiar with the Medlock real properties.
—–
FF-2-3B
[handwritten insertion: “Sandy Cobb, Ava Cobb, Joyce Parks, Christine Cobb, Johnny Jones”]
Requested and advised on fire insurance addition for [illegible word] of mortgage or a [illegible word] which burned. [Two lines of illegible abbreviations]
—–
FF-2-5A – 5D
[Editor’s note: This is a rough draft, handwritten by Eugene Chaikin, of the affidavit of Clara Johnson which appears below at FF-2-28B.]
—–
FF-28A
Still to be typed :
attempting Johnson – the rough draft has blanks throughout
Tish – what is the name you want to put there: couldn’t find her to ask
Where is Kay Nelson’s?
—–
FF-2-28B
AFFIDAVIT OF CLARA JOHNSON:
My name is Clara Johnson. I am a school teacher and I have been employed by the Los Angeles Unified School district for __ years. I am now: the Headmistress of the Jonestown Community School (a part of the public school system of Guyana) located in the North West Region of Guyana. I am __ years of age. Mabel Medlock is my aunt. Wade Medlock is my uncle by marriage. I have known both of them since __.
We all began to attend Peoples Temple of the Disciples of Christ (“Peoples Temple”, “the church”) during the _____ of 197___. During the year of 197_ we became members when the church was established in Los Angeles. My uncle Wadewas much taken with the church. He involved himself in church work including many money raising projects, and insisted that Mabel do so as well. In fact, Mabel did most of the work.
I recall that sometime in 1972 Wade and Mabel donated several hundred shares of stock to the church. Wade also wanted to donate their two parcels of real property, and, beginning early in 1973 repeatedly about his desire to donate his property to P.T. and retire to Guyana. He would say that he was old, did not need much, and wanted the money to go to a good purpose rather than to his relatives who would do nothing good with it. He was not able to get Mabel to agree and several times asked me to talk to Mabel about it. When I refused to do so he became beligerant. I was present at one occasion during this period when he spoke to one of the church attorneys, Eugene Chaikin about divorcing his wife so he could give his share to the church. I remember Mr. Chaikin advising him to consult with the church counselors and staff concerning the divorce and saying that he did not know if the church would be willing to accept a donation obtained under those conditions. I remember that Wade was very irritated with Mr. Chaikin’s response to his request.
During this same period of time Mr. Timothy O. Stoen (“Tim Stoen”) would come to Los Angeles every other weekend. Often he would stay with the Medlocks. Mabel was
—–
FF-2-28C
very pleased to have the Chairman of the Board of the Church stay with them and took very good care of him. I remember Wade telling me that he had talked to Tim Stoen about “turning the property over to the church” early in 1973.
Sometime in the summer of 1975 Wade spoke to some members of the Church about his desire to donate the properties to the church, about my refusal to assist him by talking to his companion, and Mr. Chaikin’s unwillingness to do ad [it], and about his frustration that the church was not doing anything to assist him in making the donation possible. I was there on that occasion. As I recall it took place in the main sanctuary of the church in Los Angeles and Kay Nelson and Archie Ijames were there. He then stated, as he had done on many prior occasions, that if he could not get it done any other way, he would divorce Mabel and force a sale of the properties and donate his share to the church. He was very angry at what he considered a “lack of cooperation” on the part of the church officials and attorneys.
That same night in the office of the same church a meeting was held at which the subject was discussed. Present, among others, were Enola M. “Kay” Nelson, myself, Tish LeRoy, Timothy O. Stoen, Archie J. Ijames, and Jim Jones. After the whole matter had been discussed Tim Stoen formulated a solution whereby they would each be called in separately, the situation explained, counselled and asked to deed the property over to the church with the understanding that the deeds would be used at a later date. I recall that Jim Jones did not want to have anything to do with the property and that under the circumstances it would be better if they just kept the property. Tim Stoen however pushed the [illegible word] and said he thought it would be an appropriate thing for the church to do and was probably the only way to save the marriage. In the meantime the Medlocks would live in the properties and deal with them as they always had. The next day, in the presence of myself, Tish LeRoy, Kay Nelson and others, Timothy O. Stoen called them in individually, explained the situation and asked each of them to sign deeds that he provided. Each of them did so.
During the ensuing year Wade always spoke of being satisfied with the arrangement but Mabel was displeased. She often said that she was satisfied with having made the donation, but did not like the fact that she and Wade were spoken to separately about it. I never understood her point because of the delicacy of the divorce situation, and because she signed the deeds after Wade did, and she signed the same papers he signed (deed forms) so she clearly knew he had already signed the same thing that Timothy Stoen was asking her to sign.
Later, during the winter of 1976 and spring of 1977 when Kay Nelson was showing
—–
FF-2-28D
then selling, both of the properties the Medlocks were eager to go to Guyana. They spoke to me very positively about going. I assisted them in filling out applications for passports and took them to the passport agency to get their passports which they obtained. I accompanied them on several shopping trips where they bought clothing and personal items in preparation for the trip. After their residence was sold they moved to a church owned apartment which I then managed, they paid the first two months rent. At their request I assisted them in selling much of their personal property which they would have no further use for because they were going abroad. These events took place in Los Angeles periodically throughout the spring and summer of 1977.
Originally, I guess it was in the fall or winter of 1977 but maybe as late as February of 1978, Mable did not want to go to Guyana, Her objection was that she could not take her aged mother, who then resided in Houston, Texas, with her. She did not want the donation to be completed, she said she needed her share of the funds to take care of her mother; Wade could go to Guyana, she was going to Houston, she said. Accordingly, when the sale documents were signed (I was there at the business office of the church) the instructions were made out to give her one half of the proceeds to Mable. The church agreed. Later, when Mabel was told that she could take her mother with her to Guyana she no longer had any hesitancy about going and signed papers to turn her share of the sale proceeds over to the church.
Later that summer Mable and I went to Houston, Texas, and got her mother, and returned to Los Angeles with her, in preparation to taking her to Guyana with the Medlocks. Before they completed their arrangements to go to Guyana Mabel’s mother died. Sometime after that, and in_________ first began to speak to me about the return of their funds.
I was present at each occasion that church officials spoke to church officials (except when Timothy O. Stoen was at their home) about the donation of their property. They were never threatened or coerced. As a matter of fact the church
—–
FF-2-28E
offered to return the deeds on several occasions when Mabel said she was upset with the transaction, but she always refused them. In addition the church in fact gave Mabel her share back by allowing the sales to proceed for the properties rather than recording the grant deeds. For years the church had refused those deeds, when given they were never used. The transaction originated because there was the desire that the church not come between a marriage that had lasted for_______ years. Later, the Church only agreed to accept the donations when it was clear that the Medlocks sincerely planned to go to the Church community in Guyana, where the funds would be used, in part, for their benefit.
Not only did Wade and Mable donate the proceeds from the sales of their real properties, they also donated stock and from time to time sums of cash. They assisted for years in fund raising projects. In addition, Wade was instrumental in obtaining donations from several other persons, including from my aunt Soyola [Syola] Williams.