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 AND AFFIDAVIT OF
ATTEMPTED SERVICE:
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 AND AFFIDAVIT OF
ATTEMPTED SERVICE:
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 in pursuance of the Order of Court made herein by His Honour, Mr. Justice Bishop on the 6th day of September, 1977 and in pursuance of the Writ of Habeas Corpus granted by virtue of the said order of Court, I chartered an aircraft to transport the marshal of the High Court for the purpose of effecting service of the said order of Court and Writ of Habeas Corpus.
2. That at approximately 4 PM on Tuesday the 6th day of September 1977, the Marshal of the Supreme Court and I arrived at the People’s Temple Agricultural Mission, Kaituma, North West District.
3. That on arrival at the Mission, a lady who identified herself as the personal Secretary of Jim Jones told me that Jim Jones was not at the Mission but that he was up the river. The said lady and another member of the Mission told the Marshal of the Higher
-2-
Court in my presence and hearing that Jim Jones was not at the Mission.
4. We waited and for about twenty minutes, during which time the said Marshal made several enquiries about the whereabouts of the said Jim Jones, but the answers he received were evasive. One of the answers which the personal secretary of Jim Jones gave to the Marshal was that the said Jim Jones had been away from the Mission for the two days immediately preceding Tuesday and she did not know at all where he was.
5. About twenty minutes after leaving the Mission I was introduced to two Immigration Officers of the Guyana Government at Kaituma. Both of these officers told me that they had been at the Mission earlier that day and that they had seen and talked with the said Jim Jones, during the course of certain investigations which they were carrying out.
6. The said Immigration Officers told me that they have experienced great difficulty in gaining access to and getting to speak with or see the said Jim Jones.
7. That in the premises I fear that it will not be possible for personal service of the said order of Court and Writ of Habeas Corpus to be effected in the normal manner by a Marshal of the Supreme Court.
8. That in the premises I respectfully apply to this Honourable Court for leave to effect service of the said Order of Court and Writ of Habeas Corpus in a prominent place at the Mission of the People’s Temple Agricultural Mission, Kaituma, North West District, and/or in other appropriate manner.
Sworn to at Georgetown, Demerara,
This 8th day of September, 1977,
Before Me,
/s/[illegible]
A COMMISSIONER OF OATHS