Jeffrey Haas Ex Parte Application,
September 5, 1977

Cover Sheet

1977 • No. 2584 • 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 and through her
Lawful attorney Jeffrey A. Haas, for
a Writ of Habeas Corpus and Sub judiciem,

-and-

In the matter of the Civil Law Act, Chapter 6:01

EX PARTE APPLICATION BY WAY OF AFFIDAVIT:

Page 1

1977 • No. 2584 • 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 and through her
Lawful attorney Jeffrey A. Haas, for
a Writ of Habeas Corpus and Sub judiciem,

-and-

In the matter of the Civil Law Act, Chapter 6:01

EX PARTE APPLICATION BY WAY OF AFFIDAVIT:

I, JEFFREY ALLEN HAAS, of 3609 Sacramento Street, San Francisco, California, United States of America, being duly sworn make oath and say as follows:

1. That I am an Attorney At Law admitted to practice in the State of California and am the attorney of record for Grace Lucy Stoen.

2. That as attorney of record for the said Grace Lucy Stoen I am duly authorized and have been specially authorized by the said Grace Lucy Stoen to appear on her behalf in the above-mentioned matter, and to make this application on her behalf.

3. On 23rd February, 1977, I caused to be filed in the Superior Court in and for the County of San Francisco, State of California, a Petition of dissolution of the marriage between Grace Lucy Stoen and Timothy O. Stoen. Inter Alia, a demand for custody of the infant, John Victor Stoen, aged five years was made. A file copy of the said petition is attached hereto and marked Exhibit ‘A’.

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4. That hereto attached and marked Exhibit “B” is a certified copy of the Certificate of Birth of the said John Victor Stoen, which shows that the child was born on the 25th day of January, 1972.

5. By an order of the said Superior Court made on the 26th day of August, 1977 legal custody of the said John Victor Stoen was awarded to the said Grace Lucy Stoen. A file certified copy of the said Order of Court is attached hereto and marked Exhibit “C”. There has been no appeal against the said order.

6. That I am informed and verily believe that Grace Lucy Stoen, Timothy O. Stoen, John Victor Stoen and Jim Jones are all citizens of the United States. At the time of the filing of the Petition for dissolution, Grace Lucy Stoen, Timothy O. Stoen and Jim Jones were residing in and domiciled in San Francisco, California. I am also informed by Mr. Charles Garry, attorney for Jim Jones that the said infant, John Victor Stoen was taken to the Peoples’ Temple Agricultural Mission in Guyana in October, 1976. Prior to the said removal, the infant had lived his entire life in California. Grace Lucy Stoen and Timothy O. Stoen have lived their entire married life in California. Jim Jones left San Francisco in June 1977. I am informed that he is in Guyana at the People’s Temple Agricultural Mission in North West District.

7. I have been informed by Jim Jones’ attorney Charles Garry, and Richard McCoy, First Secretary-Consul of the United States Embassy in Guyana that the said infant is with the said Jim Jones in Kaituma at the People’s Temple Agricultural Mission. The said infant remains in Guyana against the wishes and without the approval of his mother Grace Lucy Stoen and in direct violation of the said Court Order. In addition to the Superior Court granting custody to the said Grace Lucy Stoen, is further directed that the infant be brought before the Court on October 6th, 1977.

8. That repeated requests have been made for the return of the said infant. The said Jim Jones has refused and/or neglected to deliver up possession of the said infant to the said Grace Lucy Stoen and continues to do so. That I have also written

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to the attorney for the said Jim Jones demanding the return of the said child but without success. Hereto attached and marked Exhibit “D” is a copy of the said letter. That I am also informed and verily believe that the said Grace Lucy Stoen has also made repeated requests for the return of the said child but without success. The respondent had refused to deliver up possession of the said infant and continues to do so.

9. That on the 18th day of August 1977 the said Grace Lucy Stoen made a petitioner’s declaration under penalty of perjury wherein is set out some of the conditions to which the said infant is being subjected. Hereto attached and marked Exhibit “E” is a copy of the said petitioner’s declaration. The said petitioner’s declaration has been filed in the Superior Court of California and is part of the official records of the Court.

10. That I was informed by Charles Garry, the attorney for the said Jim Jones that he has advised Jim Jones to remain out of the United States of America. That I am also informed and verily believe that various Governmental Agencies in the United States of America are investigating the said Jim Jones.

11. Capt. I respectfully submit to this Honourable Court that unless the infant were removed forthwith from the possession of the said Jim Jones, irreparable harm and damage would be done to the said infant.

12. That I am advised by Counsel and verily believe that the detention of the said infant by the said Jim Jones is unlawful and that I am entitled to the possession of the said infant by virtue of the express wishes and authority of the mother Grace Lucy Stoen given to me.

13. That I accordingly apply to this Honourable Court for an order directing the said Jim Jones to deliver up to me forthwith the said infant John Victor Stoen, or for such further order or relief as to this Honourable Court may seem fit.

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14. Then I hereby authorize Mr. Henry Britton Fraser and/or Dabi Dial, Solicitor to act as my Solicitor in the above cause and to all acts and things necessary in connection therewith and to give good and valid receipts therefor on my behalf. The address for service and place of business of my said solicitor is that my office Messrs. Hughes, Fields and Stoby, Legal Practitioners, 62 Hadfield & Cross Streets, Georgetown, Demerara.

/s/ Jeffrey A. Haas

Sworn to at Georgetown, Demerara
This 5th day of September, 1977,

Before Me,
/s/ J. Budhoo
Jacnarine Budhoo

Originally posted on June 24th, 2020.

Last modified on June 26th, 2020.
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