Guyana Tribute Foundation
v. Evergreen Cemetery

The following documents – primarily in the .pdf format – are the court records in the lawsuit of Norwood v. Evergreen. For general information about the suit, see The Opposition at the brief history of the memorial.

As part of its defense – and to counter the expected declarations in support of the Guyana Tribute Foundation position – Evergreen asked the Jonestown Memorial Fund to solicit statements in support of the memorial from relatives and friends of those who died in Jonestown. More than 100 letters – addressed either to the court, to Evergreen, to cemetery owner Buck Kamphausen or to Executive Director Ron Haulman – were collected within 48 hours and included as part of the court record. Many of them are included as Letters in support of Evergreen, below.

  1. Complaint for Damages filed by Guyana Tribute Foundation and Jynona Norwood, May 10, 2011
    1. Application for Temporary Restraining Order  against Evergreen
    2. Memorandum of Points and Authorities in support of Request for Temporary Restraining Order
    3. Norwood Declaration in support of a Temporary Restraining Order 
  2. Judge McGuiness Denial of Temporary Restraining Order, May 12, 2011
  3. Judge McGuiness Supplemental Order for hearing on Preliminary Injunction, May 20, 2011
  4. Documents for Hearing for Preliminary Injunction Against Evergreen and Memorial Service, May 25, 2011
    1. Memorandum of Points and Authorities in support of Preliminary Injunction
    2. Declarations in Support of Norwood
      1. (Blank form to be filled in by supporter of Norwood)
      2. Declaration by Johnny Goodwin
      3. Declaration by Virginia Monte
    3. Proposed Order (by Norwood) Granting Preliminary Injunction
  5. Defendants’ Opposition to  Norwood Application for Preliminary Injunction, May 25, 2011
    1. Declaration of Ron Haulman
    2. Letters in support of Evergreen
  6. Alameda County Courthouse proceedings, May 25, 2011
  7. Judge McGuiness Denial of Plaintiff’s Motion for Preliminary Injunction, May 26, 2011
  8. Substitution of Jynona Norwood to Act as Attorney for Self, September 19, 2011
  9. Defendants’ Demurrer to Complaint, October 11, 2011
  10. Amended Complaint, November 7, 2011

Dr. Norwood discussed her lawsuit on several occasions outside the courtroom, including:

    • A three-part interview with John Dennis Cortez, the owner of Marin Monument Company and Amador Monument Company, with whom she contracted to design her memorial (posted on YouTube in August 2012);
    • A Call to Action on her website from October 2012, one month ahead of her annual memorial service at Evergreen Cemetery, demanding that the cemetery “tear down the Jim Jones Memorial ‘Wall of Shame'”; and
    • An article on the website of San Francisco’s public radio station KQED on November 18, 2013, the 35th anniversary of the Jonestown deaths [Editor’s note: The URL for the interview itself is defunct].

The lawsuit was dismissed in May 2014, and a state appeals court rejected lead plaintiff Jynona Norwood’s move to overturn the lower court decision. In early 2015, the court turned down Dr. Norwood’s last efforts to keep the case alive.

Other information about Jynona Norwood can be found through her website for The Miracle Wall.