TIMOTHY OLIVER STOEN
120 Montgomery Street, Suite 1700
San Francisco, California 94104
Telephone: (415) 391-5020
Attorney for Plaintiff
IN AND FOR THE COUNTY OF MENDOCINO
STEVEN A. KATSARIS,
JAMES WARREN JONES, also known as JIM JONES; SANDRA BRADSHAW, also known as SANDRA INGRAM; PEOPLES TEMPLE OF THE DISCIPLES OF CHRIST, a nonprofit corporation; PAULA ADAMS; and FIRST DOE through FIFTIETH DOE, inclusive,
AMENDED COMPLAINT FOR COMPENSATORY AND PUNITIVE DAMAGES FOR LIBEL ON ITS FACE AND FOR SLANDER PER SE
1. Plaintiff is informed and believes and thereon alleges that defendant SANDRA BRADSHAW, also known as SANDRA INGRAM, is and at all times herein mentioned was a resident of Mendocino County, California.
2. Defendant PEOPLES TEMPLE OF THE DISCIPLES OF CHRIST, was and is a nonprofit corporation organized and existing under and by virtue of the laws of the State of California.
3. Plaintiff is ignorant of the true names and capacities of defendants sued herein as FIRST DOE through FIFTIETH DOE, inclusive, and therefore sues these defendants by such fictitious names. Plaintiff will amend this complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes and thereon alleges that each of the fictitiously named defendants is responsible in some manner for the occurrences herein alleged, and that plaintiff’s damage as herein alleged were proximately caused by their conduct.
4. Defendant JAMES WARREN JONES (“JONES”), also known as JIM JONES, SANDRA BRADSHAW (“BRADSHAW”), also known as SANDRA INGRAM, PEOPLES TEMPLE OF THE DISCIPLES OF CHRIST (“PEOPLES TEMPLE”), PAULA ADAMS (“ADAMS”), and FIRST DOE through FIFTIETH DOE, inclusive, were the agents and employees of the codefendants JONES, BRADSHAW, PEOPLES TEMPLE, ADAMS, and FIRST DOE through FIFTIETH DOE, inclusive, and in doing the things hereinafter alleged were acting within the course and scope of such agency and with the permission and consent other codefendants.
5. Plaintiff is informed and believes and thereon alleges that on or about June 16, 1977 in the City and County of San Francisco, State of California, defendants, and each of them accepting defendant ADAMS, knowingly and willfully conspired and agreed among themselves to falsely defame and falsely accuse plaintiff of being a child molester should he ever attempt to meet with his daughter Maria alone, or otherwise to interfere with her allegiance to defendant PEOPLES TEMPLE as a collectivist society whose members, including Maria, would be required to devote total allegiance to the defendant JONES and to terminate on meaningful family ties (except those likely to yield inheritance monies for defendant PEOPLES TEMPLE). Plaintiff is informed and believes and thereon alleges that the efforts that conspiracy and agreement was contemplated and planned by defendant JONES many months prior thereto. Plaintiff is informed and believes and thereon alleges that one of the purposes of said conspiracy and agreement was to deter plaintiff from persisting in any such interference with Maria’s allegiance should he ever attempt to meet with her alone.
6. At all times herein mentioned plaintiff was, and now is, the director of a residential treatment center for children, and resides in the Ukiah area (Potter Valley), County of Mendocino, State of California. Plaintiff has resided in the Ukiah area for eight (8) years and at all times has enjoyed a good reputation both generally and in his occupation.
7. On May 10, 1978 defendants published a four-page press release, which is attached hereto as Exhibit A and made a part hereof. The press release stated in part:
- The statement of the “Concerned Relatives” was signed by a sordid crew of individuals who, among other things, have tried blackmail; have embezzled from Peoples Temple while infiltrating it; have even been involved in the manufacture of ammunition and have advocated ridiculous and mad schemes of violence in order to achieve revolutionary “ends” in the classic manner of agent provocateurs. Included in the group are people who have used an traffic in drugs; some who have molested children, including their own, such as Maria Katsaris just publicly exposed her father;….
8. Plaintiff is informed and believes and thereon alleges that defendant JONES on or about May 1, 1978 personally ordered, by means of international amateur shortwave radio, the publication of this press release, and by the same means dictated its exact wording. Plaintiff is informed and believes and thereon alleges that the voice of defendant JONES rendering the efforts that order and dictation was heard in the City and County of San Francisco, State of California by defendants BRADSHAW, PEOPLES TEMPLE, and FIRST DOE through FIFTIETH DOE, inclusive, who thereupon acted upon said order pursuant to the above-mentioned conspiracy and agreement. Plaintiff is informed and believes and thereon alleges that defendant JONES knew and intended that his order would be thus heard and acted upon in the City and County of San Francisco so as to result in the publication of the efforts that press release and a consequent injury to plaintiff in, inter alia, the County of Mendocino, State of California.
9. Defendants did the accent things herein alleged pursuant to, and in furtherance of, the conspiracy and agreement above alleged.
10. The publication was made of and concerning the plaintiff and was so understood by those who read the publication. Attached as Exhibit C and made a part hereof is the “statement” referred to by the above-mentioned press release. It is a 48-page document signed by plaintiff, and is entitled: “Accusation of Human Rights Violations by Rev. James Warren Jones Against Our Children and Relatives at the Peoples Temple Jungle Encampment in Guyana, South America.” It was served publicly on Peoples Temple officials in San Francisco on April 11, 1978. It is attached hereto for the purpose of showing that the publication of the above-mentioned press release was made of and concerning the plaintiff and was so understood by those who read the press release.
11. The entire press release is false as it pertains to plaintiff. Attached hereto as Exhibit B and made a part hereof is a professional polygraph report of an examination voluntarily submitted to be [by] plaintiff. In said veneration plaintiff denied ever making any sexual advances towards his daughter Maria. The report totally and unequivocally “clears” plaintiff, concluding: “it is the opinion of the examiner, based on Katsaris’ polygraph charts, that he is telling the truth.”
12. The above-mentioned press release is libelous on its face. It clearly exposes plaintiff to hatred, contempt, ridicule, and obloquy because it accuses him of the morally reprehensible crime of a lewd act on a child, and the additional crimes of extortion, embezzlement, sale of illegal drugs, revolutionary violence and every other malicious charge that the author of the press release “projected” and contrived.
13. The press release material was seen and read by persons entering and leaving the Federal Building at 450 Golden Gate Avenue, San Francisco, California on May 10, 1978. Plaintiff is informed and believes and thereon alleges that this press release was also mailed to all major newspapers, television stations, and radio stations in the State of California and the Cooperative Republic of Guyana, South America, and that it was also mailed to all members of the United States Congress and to the leading officials of the Executive Branch of the United States government in Washington, D.C., including the White House and the State Department.
14. As a proximate result of the above-described publication, plaintiff has suffered loss of his reputation, shame, mortification, and hurt feelings onto his general damages in the sum of FIVE HUNDRED THOUSAND DOLLARS ($500,000.00).
15. As a further proximate result of the above-described publication, plaintiff has suffered the following special damages: injury to his profession, all to his injury in the sum of FIVE HUNDRED THOUSAND DOLLARS ($500,000.00).
16. The above described publication was published by the defendants because of their feelings of hatred and ill will toward the plaintiff and with a desire to oppress plaintiff and this plaintiff seeks an award of punitive damages in the sum of SIX MILLION DOLLARS ($6,000,000.00).
17. Plaintiff incorporates the allegations of his First Cause of Action, including the conspiracy and agreement referred to in paragraph 5, as though fully set forth at length herein.
18. It all times herein mentioned the Press Democrat Publishing Company is, and at all times herein mentioned was, a corporation duly organized and existing under and by virtue of the laws of California and has its principal place of business in Sonoma County, California. At all times mentioned herein, the corporation was, and now is, doing business as publisher disseminator of his current events, and was and now is, publishing and circulating a daily newspaper, in the City of Santa Rosa, County of Sonoma, State of California known as the “Press Democrat”. This newspaper has a wide circulation and is read by a great number of persons and citizens of the area in which it is published and circulated, including the County of Mendocino. Defendants at all times herein mentioned were aware of the facts set forth in this paragraph.
19. On April 12, 1978 in all the additions of the Press Democrat newspaper, defendants caused to be printed, published, and circulated in the newspaper on page 1 and 15A thereof, an article which is attached hereto as Exhibit D and incorporated herein for all purposes. An excerpt of said article stated:
- Peoples Temple spokesman Sandra Ingram today said the accusations are “malicious lies.”… Katsaris also said Church officials told U.S. Embassy officials that Katsaris had sexually molested his daughter. In San Francisco today, Church spokesman Ingram said Katsaris’ daughter “will continue to state this because it is the truth.”
20. Plaintiff is informed and believes and thereon alleges that defendant JONES during the evening hours of April 11, 1978 personally ordered, by means of international amateur shortwave radio, the publication by defendants BRADSHAW, PEOPLES TEMPLE, and ELEVENTH DOE through TWENTIETH DOE, inclusive, of the above-mentioned statement attributed in the excerpt to defendant INGRAM, and by the same means dictated its exact wording. Plaintiff is informed and believes and thereon alleges that the voice of defendant JONES rendering the aforesaid order and dictation was heard in the City and County of San Francisco, State of California by each of the defendants named in this paragraph, who thereupon acted upon said order pursuant to the above-mentioned conspiracy and agreement. Plaintiff is informed and believes and thereon alleges that defendant JONES knew and intended that his order would be thus heard and acted upon in the city and County of San Francisco, State of California so as to result in the aforesaid publication and the consequent injury to plaintiff in, inter alia, the County of Mendocino, State of California.
21. Defendants did the acts and things herein alleged pursuant to, and in furtherance of, the conspiracy and agreement above alleged.
22. The efforts that the location was made of and concerning the plaintiff and was so understood by those who read it.
23. The entire statement of defendant INGRAM in the aforesaid excerpt is false as it pertains to the plaintiff.
24. The above-mentioned excerpt of the Press Democrat article is libelous on its face. It clearly exposes plaintiff to hatred, contempt, ridicule, and obloquy because it refuses him of the morally reprehensible crime of a lewd act on a child.
25. The above-mentioned article and publication was read by the readers of the newspaper at that time and on that occasion in the City of Santa Rosa, County of Sonoma, the City of Ukiah, County of Mendocino, and throughout the state of California.
26. As a proximate result of the above-described publication, plaintiff has suffered loss of his reputation, shame, modification, and hurt feelings all to his general damages in the sum of FOUR HUNDRED THOUSAND DOLLARS ($400,000.00).
27. As a further proximate result of the above-described publication, plaintiff has suffered the following special damages: injury to his profession, all to his injury in the sum of FOUR HUNDRED THOUSAND DOLLARS ($400,000.00).
28. The above-described publication was published by the defendants because of their feelings of hatred and ill will towards the plaintiff and with a desire to oppress plaintiff and thus plaintiff seeks an award of punitive damages in the sum of THREE MILLION SIX HUNDRED THOUSAND DOLLARS ($3,600,000.00).
THIRD CAUSE OF ACTION
29. Plaintiff reincorporates the allegations of his First and Second Causes of Action, including the conspiracy and agreement referred to in paragraph 5, as though fully set forth at length herein.
30. In July and August 1977 there appeared a number of magazines and newspaper articles which accused defendant JONES of employing physical and psychological coercion on the members of PEOPLES TEMPLE. Plaintiff became increasingly concerned about his daughter, Maria, who in July 1977 had traveled to Guyana, South America and was with defendant JONES. Included as part of exhibit C is a notarized affidavit of plaintiff amplifying the facts giving rise to this concern.
31. On September 14, 1977 defendant JONES and all of the defendants learned that plaintiff was planning to travel to Guyana, South America to see his daughter Maria on September 26. Plaintiff is informed and believe and thereon alleges that on or about September 20, 1977 in the city and County of San Francisco, State of California, defendants BRADSHAW, PEOPLES TEMPLE, and TWENTY-FIRST DOE through THIRTIETH DOE, inclusive, acting in concert with all other defendants by means of international telephone and amateur shortwave radio communications, and acting within the course and scope of their agency as described in paragraph 4 of this amended complaint, and with the permission and consent of the codefendants, including defendant JONES, ordered defendant ADAMS to speak the following words of and concerning the plaintiff:
- Katsaris is a child molester and sexually abused his daughter Maria. That is why Maria does not want to see him.
Immediately pursuant to the aforesaid order, on or about September 20, 1977 in Georgetown, Guyana, South America defendant ADAMS did in fact speak the aforesaid words of and concerning the plaintiff.
32. These words were heard by Richard McCoy, First Secretary of the Consulate, United States Mission to Guyana, and several other persons whose names are not known to plaintiff.
33. This publication was made of and concerning the plaintiff and was so understood by those who heard it.
34. These words were slanderous per se because they accused plaintiff of committing the morally reprehensible crime of a lewd act on a child.
35. Defendants did the acts and things herein alleged pursuant to, and in furtherance of, conspiracy and agreement above alleged.
36. As a proximate result of the above-described publication, plaintiff has suffered loss of his reputation, shame, mortification, and hurt feelings onto his general damages in the sum of THREE HUNDRED THOUSAND DOLLARS ($300,000.00).
37. As a further proximate result of the above-described publication, plaintiff has suffered the following special damages: injury to his profession, all to his injury in the sum of THREE HUNDRED THOUSAND DOLLARS ($300,000.00).
38. The above-described publication was published by the defendants because of their feelings of hatred and ill will toward the plaintiff and with a desire to oppress plaintiff and thus plaintiff seeks an award of punitive damages in the sum of THREE MILLION DOLLARS ($3,000,000.00).
Wherefore, plaintiff prays judgment against defendants, and each of them, as follows:
- 1. For general damages in the sum of $1,200,000.00.
2. For special damages in the sum of $1,200,000.00.
3. For punitive damages in the sum of $12,600,000.00.
4. For costs of suit herein incurred.
5. For such further and other relief as the court may deem proper.
DATED: May 18, 1978.
[Signed] Timothy Oliver Stoen
Timothy Oliver Stoen
Attorney for Plaintiff
Trial by jury is hereby demanded on all issues.
DATED: May 18, 1978.
[Signed] Timothy Oliver Stoen
Timothy Oliver Stoen
Attorney for Plaintiff
I, STEVEN A. KATSARIS, declare:
I am the plaintiff in the above-entitled matter.
I have read the foregoing Amended Complaint and know the contents thereof.
The same is true of my own knowledge, except as to those matters which are herein stated on information and belief, and, as to those matters, I believe it to be true.
Executed on May 22, 1978, at Ukiah, Mendocino County, California.
I declare under penalty of perjury that the foregoing is true and correct.
[Signed] Steven A. Katsaris
STEVEN A. KATSARIS
STEVEN A. KATSARIS
AN ACCOUNT OF SOME OF MY EXPERIENCES WITH PEOPLE’S TEMPLE CHURCH WHEN I ATTEMPTED TO VISIT MY DAUGHTER IN GUYANA.
In July, 1977 my daughter Maria called me from San Francisco to tell me she would be going to the People’s Temple Agricultural Mission in Guyana and would be there several weeks. She also informed me that an article highly prejudicial to People’s Temple Church was about to be published in the New West magazine and asked if I would send a telegram to the publisher in support of the Church’s work. I did so stating in a telegram that I believe they were working with people that our social system had largely neglected. Shortly after the first article appeared in New West magazine my daughter called me from Georgetown to inform me that the article was untrue, politically motivated and that I should have no concern about her activities in the Church. She also told me that she wanted to stay several more weeks in Guyana if that was agreeable with me.
At that time a number of articles appeared in newspapers concerning the experiences of some members of the Church. I became increasingly concerned about my daughter when I read that members have been subjected to various types of psychological and physical coercion. In several phone calls with my daughter I was assured that she was well and told her that in several months I would be visiting Washington D.C. on personal business and was considering going on to Guyana afterward to see her. She appeared enthusiastic and receptive to this idea.
My daughter’s letters continued to be positive mentioning that she missed me, was concerned about my health, and asked me to send out some mosquito netting and other things that she needed. Early in September 1977 I contacted the Church offices in San Francisco and ask them to inform Maria on their radio phone that I would be arriving in Georgetown on September 26. Several days passed and I received a telephone call from People’s Temple Church telling me that radio communication had not been favorable and they were unable to contact my daughter. I told them to keep trying since there was still adequate time before I would be leaving for South America. Several days later at 5:00 in the morning I received a telephone call from an unidentified person who told me that she was part of the group of people who had left People’s Temple Church. The purpose of her phone call was to discourage me from going to Guyana. She said it would probably put my daughter in a difficult position. The caller hung up before I could ask any questions. The following night again at approximately 3:00 a.m. I received another phone call. Again the unidentified caller cautioned me about going to Guyana and in more forceful terms told me that it might not be safe for me to do so. The following night I received another telephone call at approximately 4:00 in the morning. This time the caller was a man who told me I should think carefully about my decision to go to Guyana and mentioned that since I lived alone on a ranch in an isolated area my home could be burned down.
The next night on September 14 I received a radio phone call from my daughter Maria. She told me she had learned of my plans to visit her in Guyana and asked that I delay my trip until December when a group of prominent clergy would be visiting their agricultural project. The radio phone call was prolonged with many pauses and interruptions but the essence of the conversation was a series of obstacles presented to me by my daughter to discourage me from visiting. After I told her that I did not wish to travel with a group of clergy in December and that I would be going down September 26 she told me that the government of Guyana discouraged visitors due to the “tremendous harassment” that Jim Jones had been subjected to. She mentioned that he had been shot at in the jungle. I told my daughter that both she and Jim Jones knew that I would not harass them, that I had supported her membership in the Church and that I would go to the Guyanese Embassy in Washington and ask for clearance to travel to Guyana. After a pause, Maria told me that it was the policy of the Church not to permit visitors to the project. This seemed extremely strange to me since I had letters from my daughter indicating that there were daily visitors to the project. (See attached copy.) I then offered to meet Maria in Georgetown. She told me she would not be in Guyana but would be in Venezuela during the time of my intended visit. I suggested meeting her in Venezuela but she said she could not see me there since she would only be in that country several days and wanted to spend that time with her fiancé. Her fiancé’s name reportedly was Larry who was the medical officer for the agricultural project. I have since learned that another parent Sherwin Harris has been told that his daughter in Guyana is married to the same doctor. I interpret this ploy as a rather crude attempt to assure parents that their children in the Church are well and married or about to be married to fine professional people. The radio phone call was extremely strange and cause me great anxiety because it did not sound like my daughter was free to speak for herself and certainly her choice of words did not appear natural. The long pauses in the conversation made me suspect she was being coached. When I finally told her that I was upset and frightened and that I would use every legal and diplomatic means to see her she replied that she would not see me even if I did come to Guyana.
The following day I sent a telegram to Rev. Jim Jones telling him of my concern and asking for his reply. (Copy attached.) No reply was ever forthcoming.
Shortly afterwards I left for Washington D.C. where I contacted John Matheny, Military Advisor to Vice President Mondale, and Frank Tuminia of the Guyanese Desk of the State Department. I told them of my concern and solicited their help. I also went to the Guyanese Embassy and was assured that I could travel to Guyana. When I arrived in Georgetown I first went to the United States Embassy and made contact with Mr. Richard McCoy. He showed me a handwritten transcript that was delivered to the Embassy by People’s Temple Church member Paul Adams. The message claimed to be from my daughter and had been received in Georgetown via radio phone. It stated that Maria was happy, she was twenty-four years old, engaged to be married and had had a traumatic childhood and did not wish to see her father. Mr. McCoy stated that Paula Adams volunteered background information on me saying I was a child molester and had sexually abused my daughter and offered that as a reason that Maria did not want to see me. After an unsuccessful attempt to make contact with my daughter in the interior I returned to Washington D.C. and related my concern to the State Department, Senator Hubert Humphrey’s office, Senator Cranston’s office, Congressman Phillip Burton’s office, Congressman Lawson’s office, the Vice President’s office, and the International Human Rights Commission’s office.
After my return to California I contacted and personally interviewed as many former members of People’s Temple Church as would speak with me. To my dismay I learned that my daughter had been received into the innermost governing body of People’s Temple Church and held the position of influence and intimate knowledge of the workings of the movement. I further learned from former members that she was responsible for large amounts of money and while in San Francisco would on occasion have upwards of $200,000.00 in cash and checks in her room at the Temple. I ascertained from people who had firsthand knowledge that Maria had been required to sign an undated suicide note that could be used to explain her disappearance should she ever attempt to leave the Church. In addition to this she had signed statements incriminating herself and her family of various imagined bizarre misdeeds. I was further told by a former member of the Church that she and Maria had been required to sign statements that the Children’s Residential Treatment Center that I direct was involved in a gigantic welfare fraud, that it was staffed by child molesters and homosexuals, that I myself was a child molester, and had sexually abused one of the girls in the program and that the children in our care were being abused. I was also told that my daughter’s life could be in jeopardy if People’s Temple Church thought that she was about to defect. In view of the threatening phone calls that I have received, this appeared to be a definite possibility. After speaking with Mr. Robert Chilamidos an investigator for the State of California, with Mr. James Hubert investigator for the United States Treasury Department, and Mrs. Jan Tespool an investigator for the Mendocino County Sheriff’s Department I lived in constant anxiety for my daughter’s safety. I was convinced that People’s Temple Church was using their humanitarian efforts and social welfare activities to cover for their ultimate goal which is the establishment of world socialism (fascism?) with Jim Jones as their leader and that they would stop at nothing including calumny, character assassination, blackmail, threats of violence and even murder to achieve their goal. In early November I made another trip to Washington D.C. where I convinced Guyanese Ambassador Lawrence [Laurence] Mann to arrange a meeting between my daughter and me. He went to Georgetown and while there called me and told me that Rev. Jones had agreed to the meeting and assured him that he wanted the members of his Church to have the closest possible relations with their families. I was told to come to Georgetown which I did the following day. Ambassador Mann met me at my hotel in Georgetown, told me that Maria would be in the following day and that he had arranged to take Maria, Mr. McCoy from the United States Embassy and me to dinner as his guests. After the dinner he and Mr. McCoy would depart and Maria and I could have the opportunity to speak privately. Maria did not arrive as planned and the Ambassador phoned me explaining that the Church was having difficulties getting her to Georgetown from the interior. The following day I was given the same story. And finally by Saturday of that week the Ambassador called and told me that Maria would be arriving at 4:00 p.m. At 6:00 p.m. that day the Ambassador again called, appeared somewhat irritated and said he had been informed by the Church’s office in Georgetown that Maria had arrived but was not feeling well and could not go to dinner. I immediately called the Church offices and asked to speak with my daughter. I was told to wait and after a considerable delay was told that Maria was not there and had gone out to dinner. I asked that she call me at my hotel when she returned and was assured that she would. I did not receive a telephone call on Saturday night. However, at 7:15 Sunday morning I was informed by a representative of People’s Temple Church that Maria would meet with me in 45 minutes. Ambassador Mann and Mr. McCoy were at the meeting when Maria arrived with four other persons, two men – one who identified himself as an attorney representing the Church – and two women. Maria appeared agitated, could not look me in the eye, and did not return my embrace which appeared unusual and even ominous to me. She looked as if she had not slept well or had been deprived of sleep over a long period of time and the general attitude was one of suspicion, hositility [hostility], and paranoia. She accused me of causing trouble for the Guyanese government and stated that because of my efforts Guyana had been black listed by the International Human Rights Commission. She stated further that the Church had been informed by the United States government that I was a member of a conspiracy against the Church and was associated with a right-wing congressman who intended to destroy the Church. She accused me of lying to her about my health. When I pointed to Paula Adams, one of the women who accompanied her to the meeting, and asked if she knew that this woman had gone to Mr. McCoy and told him that I had abused my daughter sexually, Maria refused to discuss the subject. When I told her that I had information that she had signed an undated suicide note, she demanded to know the source of my information. I told her that was not the important issue and that she could alleviate my anxiety by simply telling me it was not true. She replied that since I would not reveal the source of my information she would not discuss that subject. In the course of the conversation with Maria I told her that before leaving for Guyana I had spoken with Grace Stoen who wanted me to convey her love and concern to her son John. Maria told me that Grace an unfit mother and she had abused her child and that Maria was now the mother for John. She also told me in a tone that I did not believe possible from my daughter that if Grace made any attempt to get her child back she would be sorry. My daughter’s affect and the manner in which she spoke conveyed to me the tone of a serious threat. The entire meeting was extremely painful for me and depressing. I managed to tell my daughter that if she ever wanted to return home a ticket would be waiting for her at the Embassy. When I told her of my belief in God and that somehow things would work out, she and another woman from the Church were quick to point out to me that they do not believe in God.
After the meeting I went to the airport to catch a flight to New York City. At the airport I received a message to call Mr. McCoy. In our telephone conversation he told me that both he and Ambassador Mann were disturbed by the meeting and believed that something strange was happening since he could see no reason why the Church should take that attitude toward me. He told me that he would write to me, but to this date I have received no communication from him. After arriving in New York City I proceeded to Washington D.C. where I spent numerous days contacting as many people in the government as I thought would help me. Most were sympathetic but were quick to point out that since my daughter is 24 years of age and since it appears that she is in Guyana voluntarily there is little they could do to help me.
Since November I have received no communication from Maria and have not attempted to make contact with her since I believe this might be interpreted either as an attempt on my part to get her out of the Church or as a sign that Maria is wavering and is about to defect and might place her life in jeopardy.
[Signed] Steven A. Katsaris
Steven A. Katsaris
Trinity School for Children
April 4, 1978
State of California,
County of Mendocino
On April 4, 1978, before me, the undersigned, a notary public in and for said State, personally appeared Steven A. Katsaris known to me, to be the person whose name is subscribed to the within instrument, and that knowledge into me that he executed the same.
Witness my hand and official seal.
[Signed] Dorothy B. Martin
Notary Public in and for said State