Lawsuitcross

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

CORNELL CROSS, II
Plaintiff

vs.

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

Case No. CJ 2007 07821 (stamp)
JEFFERSON D. SELLERS (stamp)

ATTORNEY LIEN CLAIMED
JURY TRIAL DEMANDED

ORIGINAL (stamp)

PETITION

I.
PARTIES JURISDICTION’S AND VENUE

1) The Plaintiff is a student at Oral Roberts University in Tulsa, Oklahoma. The Defendants - Oral Roberts University (ORU) and Oral Roberts Ministries (ORM) . are Oklahoma Corporations. The Defendants -The Board of Regents of Oral Roberts University and The Board of Directors of Oral Roberts Ministries - are the governing bodies responsible for oversight of the Defendant Corporations. Richard Roberts is the President and CEO of ORU and is the CEO of ORM. Lindsay Roberts is an ORU Regent and an ORM Director. The Causes of Action arose in Tulsa, Oklahoma and this Court has jurisdiction over the Parties and subject matter.

II.
FACTUAL ALLEGATIONS

2) The Plaintiff; Cornell Cross, enrolled at Oral Roberts University for the Spring semester of 2005, after moving to Tulsa, Oklahoma from South Berlington, Vermont. He did so because of ORU a reputation Plaintiff’s original major was Theology, and planned to join the Air Force as a Chaplain. However, his original endeavor changed after Plaintiff met Dr. Timothy Brooker during an initial Government class. Thereafter, Plaintiff changed his major to Government, after which he joined a group of ORU students in a political policy conference in Washington D.C. Many doors opened through the assistance of Dr. Brooker and Dr. Swails of ORU’s Government Department. Plaintiff was able to meet the U.S. Senator from his home state, Patrick Leahy. More opportunities developed for Plaintiff and other Government majors. which allowed them to directly lobby U.S. Representatives and Senators, Through the efforts of the Government program, more doors were opened in the political arena, Soon thereafter, Plaintiff became a leader on campus. During this period, the ORU Government program quickly grew from 15 majors to more than 200 majors, making Government the fourth largest major on Campus.

3) During the Summer of 2006, Plaintiff was hired to work on two national campaigns and received various national positions as a result of his continued involvement with the Government program at ORU. Thereafter, Plaintiff was hired by Major General Martha Rainville in her campaign for Congress in Vermont, This transpired because of his ongoing training, education, and experience with the ORU Government program. However, due to the illegal and tortious conduct of the Defendants, the Internal Revenue Service blocked all campaign involvement by ORU students until after the 2006 campaign season. As a result, the Plaintiff lost his internship, and the Candidate lost her experienced campaigner and priceless Government students who were hired to work on her campaign.

4) Plaintiff announced his candidacy for office and was elected as Vice President of Graduates and Commuters at ORU. Thereafter, Plaintiff attempted to learn about the finances of the Defendants, after which his attempts were thwarted and he became a target of the Administration for expulsion.

5) In the Spring of 2007, ORU essentially gutted the Government Department through its wrongful terminations of the various professors who were responsible for building that Department: Dr. Swails, Dr. Timothy Brooker, and Dr. Paulita Brooker. Thereafter, the Administration wrongfully attempted to remove Plaintiff from campus through various means. Furthermore, the conduct of the Defendants has now devalued and ruined the reputation of any college degree that the Plaintiff might obtain from ORU. Finally, Plaintiffs attempts to transfer to another university will essentially invalidate approximately fifty percent of his college credits and cause him to become further indebted as a result of the conduct of the Defendants.

III.
CAUSES OF ACTION

FRAUD

6. Prior to and during the Plaintiff’s tenure at Oral Roberts University, the Defendants provided false and misleading material information to the Plaintiff, with the intention that it be acted upon by him. Furthermore, the Defendants knowingly failed to provide thorough and truthful information regarding the Defendants, ORU/ORM. The result of this deceit was that the Plaintiff was induced to enroll and complete the majority of his college hours at Oral Roberts University’ pursuant to false pretenses, misrepresentations and omissions, The Plaintiff justifiably relied upon this fraudulent information and misrepresentations to his detriment, and continues to suffer damages.

TORTIOUS INTERFERENCE WITH BUSINESS RELATIONSHIPS

7) The Defendants, in their official capacities, conspired and individually acted to interfere with the Plaintiffs business relationships. 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.

CIVIL CONSPIRACY

8) The Defendants conspired to commit the Torts complained of herein upon the Plaintiff during covert and unauthorized formal and informal meetings and conversations, and carried out their plan, after which they initiated a smear campaign against the Plaintiff in order to further insulate themselves from exposure, liability, or the consequences of their egregious conduct.

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

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

NEGLIGENCE

10) The ORU Board and the OEM Board have exhibited a consistent pattern of negligence regarding their fiduciary and oversight duties to authorize and supervise the conduct of the other Defendants, a duty which they miserably breached. In fact, their lack of participation is apparently a function of their own fiscal improprieties, which are now the subject of an investigation by the United States Senate.

IV.
REQUEST FOR RELIEF

11) Plaintiff seeks actual damages in excess of $10,000. punitive damages in excess of $10,000, attorney’s fees, court costs, prejudgement interest arid 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. OBAF 990
6450 South Lewis Avenue, Suite 300
Tulsa, Oklahoma 74136
(918)492-7674 / (918) 493-1925 fax
(Attorneys for Plaintiffs)

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