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IN THE DISTRICT COURT IN AND FOR TULSA COUNTY
STATE OF OKLAHOMA

TRENT HUDDLESTON
Plaintiff,

ORAL ROBERTS UNIVERSITY, an Oklahoma Corporation;
ORAL ROBERTS MINISTRIES, and Oklahoma Corporation;
THE BOARD OF REGENTS OF ORAL ROBERTS UNIVERSITY;
THE BOARD OF DIRECTORS OF ORAL ROBERTS MINISTRIES;
RICHARD ROBERTS, ORU President and CEO of Oral Roberts Ministries; and
LINDSAY ROBERTS, ORU Regent and ORM Director.
Defendants,

Case No. CJ 2007 07819 (stamp)
DEBORAH C. SHALLCROSS (stamp)

ATTORNEY LIEN CLAIMED
JURY TRIAL DEMANDED

PETITION

COMES NOW the Plaintiff, Trent Huddleston, and for his causes of action against the Defendants, alleges and states:

I.
PARTIES, JURISDICTION. AND VENUE

1) The Plaintiff, Treat Huddleston. is a resident of Tulsa, Oklahoma, where his causes of action arose. The Defendants, Oral Roberts University and Oral Roberts Ministries, are Oklahoma Corporations, doing business in Tulsa, Oklahoma. The Defendants, The Board of Regents of Oral Roberts University and The Board of Directors of Oral Roberts Ministries, are the supervisory and governing bodies who are responsible for the activities of the previously named corporations. Richard Roberts was the President of Oral Roberts University during all relevant times, and is currently the CEO of Oral Roberts Ministries, Lindsay Roberts is a member of The ORU Board of Regents and The ORM Board of Directors.

II.
FACTUAL ALLEGATIONS

2) Plaintiff, Trent Huddleston, was hired by the Defendants, Oral Roberts University and Oral Roberts Ministries, in July of 2006 as a Senior Accountant, The Plaintiff’s job description, among other things, included the responsibility for recording the fixed assets of the University and delegating those assets to several different corporations which were previously formed by the Defendants. During the Plaintiff’s tenure, he was improperly and unlawfully directed to perform functions and duties in violation of State and Federal law in an effort by the Defendants to “cook the books”, and hide from the appropriate authorities and the public, the continued wrong doing, improper and illegal conduct of the Defendants, and in particular, of Richard and Lindsay Roberts.

3) For example, during the approximately fifteen months of Plaintiff’s employment, he was directed, against his will, and over his objections, to falsely list thousands of dollars as expenses rather than assets, which were spent remodeling the home of Richard and Lindsay Roberts, in order to defraud the IRS, OTC, and the public, on behalf of the Defendants, and in particular for the protection of the Defendants, Richard and Lindsay Roberts, who co-mingled and spent the assets of the Defendants and utilized the same as their own personal funds through 2007.

Expenditures of $122,886.24 were paid by ORU/ORM for remodeling the residence of Richard and Lindsay Roberts, in excess of $40,000 was spent by ORU/ORM for a new swimming pool. $4,780 was spent by ORC/ORM on a pool table, and funds were paid by these corporations for the Roberts’ “wet bar”, These are only a few of the items which were falsely listed by the Defendants for tax purposes, while, at the same approximate time, faculty members were directed by the Defendants to buy their own copy paper due to an alleged tight budget.

4) Plaintiff herein further alleges that he was wrongfully constructively discharged on the day an audit was to take place because of his well known propensities and history of questioning and challenging, the things that occurred within the accounting department where he served as Senior Accountant. This “audit” was requested by the Board of Regents two weeks following a lawsuit filed against the University and others by three former professors, who also divulged improper expenditures of Oral Roberts University officials and specifically those of the President of the University. Plaintiff Huddleston was stymied on numerous occasions from seeking answers to his questions about certain expenditures and the reasons therefore, in his effort to make proper and appropriate entries, based upon proper accounting procedures and principles. However, Plaintiff was specifically instructed not to contact certain departments or individuals at all about expenditures, even though the expenditures at issue included thousands of dollars annually.

Furthermore, Plaintiff was not allowed to question the authenticity of the expenditures or their legitimacy. Plaintiff was, on one specific occasion, called in by his supervisor, admonished, and told that Plaintiff was harassing, by simply leaving two telephone messages with a particular party, wherein he was seeking necessary information about expenses. Defendants were well aware of the fact that Plaintiff was subject to exposing these methods of secrecy and questionable accounting practices. Therefore, Defendants created a subterfuge situation that would obviously result in Plaintiff making this planned and timely exit from the University.

III.
CAUSE OF ACTION

CONSTRUCTIVE DISCHARGE

5) The Plaintiff was constructively discharged by the Defendants after fifteen months of intimidation and harassment, During the course of Plaintiff’s employment, he continued to complain about the Defendants’ requirements that he violate public policy, state and federal law, and that he defraud the authorities, the public, and in particular, those who donated money for purposes other than for which it was fraudulently used by Richard and Lindsay Roberts. For example, funds donated by one church were spent specifically upon the Roberts’ residence. Thereafter, Plaintiff’s constructive discharge was accomplished in retaliation for his refusal to remain silent about the fact that the Defendants were committing illegal acts with regard to the finances of the various Parties. The Defendants allowed the Plaintiff’s working conditions to become so intolerable that a reasonable person in the Plaintiff’s situation would feel that he had no choice but to quit.

FRAUD

6) Prior to and during the course of Plaintiffs employment, the Defendants provided false and misleading material information to the Plaintiff, with the intention that it be acted upon by the him. Furthermore, the Defendants knowingly failed to provide thorough and truthful information regarding the ongoing criminal conduct of the Defendants regarding their finances and the co­mingling of the same, The result of this deceit was that the Plaintiff was induced to accept employment and continue employment pursuant to false pretenses, misrepresentations and omissions. The Plaintiff justifiably relied upon this fraudulent information and representations to his detriment, and continues to suffer damages. Furthermore, the Defendants, and in particular Richard Roberts, have continued to lie about these matters to the public and presumably to the authorities, in a continued and pathetic attempt to save Roberts’ administration.

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

7) The Defendants’ actions in the setting in which they occurred were so extreme and outrageous that their conduct went beyond all possible bounds of decency, and would be considered atrocious and utterly intolerable ins civilized society. The Defendants intentionally or recklessly conspired to cause severe emotional distress to the plaintiff, beyond that which a reasonable person would be expected to endure.

NEGLIGENCE

8) Oral Roberts University, The Board of Regents of Oral Roberts University. Oral Roberts Ministries and The Board of Directors of Oral Roberts Ministries have exhibited a consistent pattern of negligence regarding their fiduciary and oversight duties to supervise the conduct of the other Defendants, before, during and since Plaintiffs termination.

CIVIL CONSPIRACY

9) The Defendants conspired to tortiously violate the rights of the Plaintiff during covert and unauthorized formal and informal meetings and Conversations, after which they carried out their plans and terminated Plaintiff.

TORTIOUS INTERFERENCE WITH BUSINESS RELATIONSHIPS

10) The Defendants, in their official capacities, conspired and individually acted to interfere with the business relationships of the Plaintiff. This interference was not undertaken in good faith or for a bona fide organizational purpose, but was a malicious, improper and intentional plan to harm and damage the Plaintiff

IV.
REQUEST FOR RELIEF

11) The Plaintiff seeks actual damages in excess of $10,000, punitive damages in excess of $10,000. attorney’s fees, court costs, prejudgement interest, and any further relief that the court deems just and equitable.

Respectfully Submitted,

RICHARDSON LAW FIRM, P.C.

Gary L. Richardson, OBA#7547
Paul T. Boudreaux, OBA# 990
6450 South Lewis Avenue, Suite 300
Tulsa, Oklahoma 74136
(918) 492-7674 / (918) 493-1925 fax
(Attorneys for Plaintiffs)

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