Secondpetition

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

stamp(FILED Oct 12 2007 SALLY HOWE SMITH, COURT CLERK STATE OF OKLA TULSA COUNTY)

DR JOHN SWAILS, DR TIM BROOKER, and DR PAULITA BROOKER,
Plaintiffs,

vs.

ORAL ROBERTS UNIVERSITY, an Oklahoma Corporation, DR RICHARD ROBERTS, ORU President, DR MARK LEWANDOWSKI ORU Provost, DR WENDY SHIRK ORU Dean, DR JEFF OGLE, ORU Associate Provost, and THE BOARD OF REGENTS OF ORAL ROBERTS UNIVERSITY
Defendants.

Case No. CJ 2007-06543

Judge Rebecca Brett Nightingale

SECOND AMENDED PETITION

COME NOW the Plaintiffs, Dr. John Swails, Dr. Tim Brooker, and Dr. Paulita Brooker, and for their causes of action against the Defendants: Oral Roberts University, Dr. Richard Roberts, Dr. Mark Lewandowski, Dr. Wendy Shirk, Dr. Jeff Ogle, and The Board of Regents of Oral Roberts University, allege and state:

I.
PARTIES. JURISDICTION. AND VENUE

The Plaintiff, Dr. John Swails, (hereinafter SWAILS) has served at Oral Roberts University, (hereinafter ORU) in excess of 14 years, where he was a Tenured Professor and Chair of the Department of History, Humanities, and Government. The Plaintiff, Dr. Tim Brooker, (hereinafter T BROOKER) was also a Professor at ORU since August of 2001, where he was hired to coordinate the Government program. The Plaintiff~ Dr. Paulita Brooker, (hereinafter P BROOKER) was an Adjunct Professor in the Department of History, Humanities and Government at ORU from August of 2004 until August of 2007. She became a full-time employee in the School of Lifelong Education in February of 2006, after being lured to ORU from her previous position with The Siloam Springs Housing Authority; a position in which she was fully vested and in which she had accumulated eleven years of seniority.
The Defendant, ORU, is an Oklahoma Corporation, which was incorporated in November of 1963, and is located and doing business at 7777 South Lewis Ave., Tulsa, Oklahoma. The Defendant, Richard Roberts, (hereinafter ROBERTS) is the President of ORU and has served in that capacity for approximately 13 years. The Defendant, Mark Lewandowski, (hereinafter LEWANDOWSK1) is the current Provost of ORU and has filled that position since May of 2007. The Defendant, Wendy Shirk, (hereinafter SHIRK) is the Dean of The College of Arts of ORU and has filled that position since May of 2007. The Defendant, Jeff Ogle, (hereinafter OGLE) is the Associate Provost and Former Vice President of Student Services at ORU, and has filled those positions for approximately a decade. The Defendant, The Board of Regents of Oral Roberts University (hereinafter The BOARD) collectively compose the Corporate Directors of ORU.
All causes of action arose in Tulsa, Oklahoma. This Court, therefore, has jurisdiction over the subject matter and Parties. Venue is also appropriate.

II
FACTUAL ALLEGATIONS

Plaintiff, T BROOKER, with a background in the fields of Diplomacy, Public Policy and Administration, Campaign Management, Talk Radio, and Mental Health Counseling was hired by ORU in August of 2001 to become the Coordinator of the Government Program of the Department of History. Humanities and Government Department. Under his leadership, the Government Program quickly gained national recognition in the area of Practical Politics. His reputation increased to such extensive proportions that he was personally approached by the Republican National Committee, (hereinafter RNC) to be exclusively considered for a pilot program that the RNC hoped to implement The RNC selected T BROOKER and ORU as the University to explore the development of this program in an effort to further Republican political efforts. T BROOKER, along with students from ORU, were involved in numerous political efforts during the next few years and experienced great success in these endeavors. However, all of this activity involved Political races outside the State of Oklahoma; with all costs and expenses paid by the RNC, or another individual campaign committee. This arrangement maintained the compliance requirements of state and federal laws, including Internal Revenue Code (hereinafter IRC) section 501 (c) (3) in preservation of the tax exempt status which was enjoyed by ORU. This strategy of gaining service-learning experience only outside of Oklahoma was a consistent and well-known position by T BROOKER. Every Government student knew Dr. Brooker’s mantra: “We don’t do local politics because it turns neighbors into enemies.”
In December of 2005, T BROOKER was summoned to the Office of ORU President ROBERTS for a meeting with ROBERTS along with Stephanie Cantese, (hereinafter CANTESE) ROBERTS’ sister-in-law, who held the position of Community and Governmental Liaison for the Oral Roberts Ministries. During this meeting, ROBERTS instructed T BROOKER that it was time to utilize the talent and resources of T BROOKER and his students in local political races. ROBERTS cited a Bible text about “First Judea, then Samaria, and then to the uttermost parts of the Earth” as his rationalization for directing T BROOKER to become involved in a race in ROBERTS’ hometown. ROBERTS then directed T BROOKER to become involved in the Republican Primary for the office of Mayor of the City of Tulsa on behalf of Randi Miller—whom ROBERTS and CANTESE had recruited and were supporting. At this point, T BROOKER resisted, explaining to ROBERTS the implicit improprieties and the clear boundaries required by state and federal law, including IRC section 501 (c) (3); as well as the great danger of “turning neighbors into enemies.” However, ROBERTS, nonetheless, was undaunted by the applicable law and the offered counsel and persisted in his plan. Thereafter, during a subsequent meeting with ROBERTS, and accompanied by his entire chain-of-command, Plaintiff SWAILS, Dean George Thyvelikakath, and then-Provost Ralph Fagin, T BROOKER again advised ROBERTS—and his supervisors—of the potential pitfalls and improprieties of ROBERTS’ intended course of action. Unfortunately, ROBERTS remained adamant in his position and again directed T BROOKER to follow ROBERTS’ directive. This edict from ROBERTS, on behalf of ORIJ and as President of the Corporationwherein university funds and resources would be used to favor a candidate in a contested partisan race—was a direct violation of state and federal law, which expressly prohibits a tax exempt organization, such as ORU, from becoming involved in contested partisan political campaigns. This involvement in a local campaign, as directed by ROBERTS, substantially differed from previous out-of-state efforts, in that the expenses of T BROOKER and the ORU students were born by the RNC or another contracting campaign. In this instance, T BROOKER was informed by CANTESE that his ORU students “should be glad to work for Randi Miller for free.” Furthermore, ROBERTS’ edict and directive was in direct violation of the Articles of Incorporation of ORU and the Faculty and Administrative Staff Handbook and Policy Statement of ORU.
In May of 2006, ORU was contacted by the United States Department of the Treasury and Internal Revenue Service, concerning a complaint it had received about ORU’s involvement in a local political endeavor. The IRS was investigating a potential violation of the 501(cX3) status that ORU enjoyed. Within that directive, ORU was required to respond to a series of Interrogatories. The IRS was specifically interested in any involvement by ORU’s administration
including ROBERTS-as well as, the reasons for the participation of ORU students in the Randi Miller Campaign. Therefore, Plaintiff T BROOKER was tasked with devising a narrative whereby Plaintiff T BROOKER would “fall on the sword” and accept full responsibility for all local political involvement. T BROOKER was instructed to cover-up the directives of ROBERTS, and ordered to accept complete, total and full responsibility for the campaign involvement he had so vigorously opposed. Therefore, T BROOKER constructed two draft narratives in an attempt to provide then-Provost Ralph Fagin, pursuant to his direct instruction, with a document which would explain student involvement without disclosing the central role of ROBERTS in the events. Only after the third version of the narrative did three ORU Vice-Presidents—as well as ORU’s Chief Legal Counsel—accept the verbiage. Then-Provost Fagin utilized his own sanitized and inaccurate narrative-replete with incomplete and inaccurate information—to construct a sworn affidavit in response to the IRS’ questions; despite his full knowledge of ROBERTS’ central role in ordering student involvement in the Randi Miller Campaign. Then-Provost Fagin’s sworn statement, executed under oath and on behalf of ORU, willfully and intentionally excluded the fact of ROBERTS’ explicit instructions to T BROOKER. The result of this process was a complete coverup by ORU and its Officers of all potential violations of federal and state laws with regard to illicit university support for the Randi Miller campaign. Defendants then accelerated their cover-up by initiating a series of punitive actions towards T BROOKER, in a transparent effort to insulate their own culpability, by disciplining T BROOKER for his involvement in the Tulsa Mayoral race-even though T BROOKER’s involvement had been duly ordered over his objections. To this end, ORU refused to pay T BROOKER substantially earned salary of approximately $18,000 for teaching administratively-approved summer school courses. Further, T BROOKER suffered excessive and unnecessary harassment, loss of academic freedom, endured retaliatory and punitive conduct, and was subjected to public humiliation generated by Defendants on local and national levels.
During the previously described period of time, an ORU student working for the Randi Miller campaign provided to Plaintiff T BROOKER, a compilation of damaging information regarding Defendants, ORU and ROBERTS. This compendium itemized numerous and substantial acts of misconduct and improprieties by the Defendants, ORU and ROBERTS. The material had been drafted and developed by CANTESE, in her position and within the scope of her employment as Community and Governmental Liaison for Oral Roberts Ministry. This internal document, according to published reports, was apparently provided to ROBERTS at some point during 2004. CANTESE’S documents appear to comprise a confidential assessment of potential vulnerability for legal, moral, political and ethical problems of the Roberts family, Oral Roberts Evangelistic Association and Oral Roberts University for specific legal, moral, ethical, and financial lapses. T BROOKER, understanding the serious nature and apparent reliability of CANTESE’S Report, immediately delivered it to his Supervisor, Plaintiff SWAILS. Thereafter, upon prayerful consideration for approximately two weeks, Plaintiff T BROOKER then provided the CANTESE Report to ORU Provost Ralph Fagin, who ultimately confronted ROBERTS with this voluminous collection of impropriety. Soon thereafter, T BROOKER received threats from CANTESE, in her capacity as The Community and Governmental Liaison for the Oral Roberts Ministry. CANTESE’S threats included the termination of his wife, Plaintiff P BROOKER, from her then-new position at ORU, the termination of Plaintiff T Brooker, harm to the BROOKERS’ children, and difficulties for the students enrolled in T BROOKER’s programs.
Unfortunately, neither ORU nor ROBERTS performed any investigative or remedial action. This substantial documentation, alleging immoral and improper conduct, was handed to members of The BOARD on July 16, 2007, by Plaintiffs SWAILS and T BROOKER. The exact packet of information submitted to the ORU Board by Plaintiffs SWAILS and T BROOKER is attached hereto as “Exhibit A.” (Bates Stamped pages 1 through 17). After waiting fourteen months for action—and fearing the CANTESE Report was about to be released by students in possession of an original copy—T BROOKER and SWAILS provided “Exhibit A” to The BOARD, which did much hand-wringing, but took no action whatsoever. This reporting of wrongdoing to the governing body of the university immediately preceded the termination of all three Plaintiffs by Defendant ROBERTS and the other herein named Defendants. Thereafter, Defendants conspired to discredit and rid themselves of Plaintiffs by engaging in improper and deceitful conduct, in an obvious attempt to insulate themselves from their inappropriate and illegal conduct The ORU BOARD remained as spectators, and passively watched as all three Plaintiffs were savaged both personally and professionally by those ostensibly under their collective supervision and control.

III
CAUSES OF ACTION

1) BREACH OF CONTRACT/WRONGFUL DISCHARGE

The Plaintiffs were employed pursuant to various written and oral contracts with ORU. However, the Defendant, ORU, b~reached its contractual obligations and agreements with the Plaintiffs, wrongfully terminating both SWAILS and P BROOKER, and wrongfully causing the resignation and constructive discharge of T BROOKER, through intimidation, harassment, and intentionally making or allowing T BROOKER’S working conditions to become so intolerable, that a reasonable person in T BROOKER’S situation would feel that he had no choice but to resign.
On August 28, 2007, SWAILS was wrongfully discharged by Defendants, LEWANDOWSKI and ORU, at the apparent direction of ROBERTS, in violation of SWAILS’ contract and ORU’s Policies and Procedures. Furthermore, LEWAM)OWSKI impounded SWAILS’ office, needlessly directed two Security Guards to publicly humiliate and escort him from the building, barred him from reentering the campus, and confiscated and refused to return any of SWAILS’ personal property, including his personal computer files. Defendant SHIRK was determined to persecute, humiliate and discharge T BROOKER, based upon factually inaccurate, anonymous reports and in the face of massive disconfirming evidence. Plaintiff T BROOKER was constructively discharged by ORU, ROBERTS, and SHIRK, although she had never met, or even spoken with T BROOKER, prior to his constructive discharge. Following the wrongful termination of T BROOKER, in clear violation of the terms of his contract with ORU, Plaintiff T BROOKER had hoped—and even attempted—to resolve this conflict without public attention or further scrutiny upon the Defendants. However, his efforts to do so became impossible as a result of ORU’s contemporaneous and wrongful termination of T BROOKER’S wife, Plaintiff P BROOKER, and Tenured Professor, Plaintiff SWAILS. Thereafter, ORU began disseminating damaging and false gossip and information about T BROOKER, causing ORU students and others to question the integrity of the Plaintiffs.
P BROOKER was wrongfully discharged in May of 2007 by Defendants, OGLE and ORU, in violation of ORU’s Policies and Procedures, and in breach of both oral and written contractual agreements. In April of 2006, CANTESE, on behalf of the Oral Roberts Ministry and the ROBERTS Family, pledged to destroy Plaintiff P BROOKER’s career if all copies of the incriminating documents were not returned to her.
Plaintiffs additionally allege, upon information and belief, that P BROOKER was wrongfully discharged by OGLE in retaliation for the reporting of OGLE’S ongoing sexual harassment of a young, female professor in Plaintiff SWAILS’ Department In protection of a young teacher, Plaintiff SWAILS had convinced to join the faculty at ORU, Plaintiff SWAILS refused to drop his subordinate’s harassment claim against a powerful vice-president, and informed Defendant LEWANDOWSKI and Defendant SHIRK of his intention to fully investigate his subordinate’s claims of sexual harassment and seek justice on her behalf. However, Defendant ORU performed no investigation, took no action and forced the resignation of the victim. This young professor has since left academia, and even left the country. In point offset, Defendant LEWANDOWSKI sent a chilling message to female ORU employees by terminating the complaining victim and then immediately promoting the alleged perpetrator: Defendant OGLE. Plaintiff P BROOKER was the only one of the Plaintiffs who worked directly for Defendant OGLE. P BROOKER asserts that her firing was partially in retaliation for Plaintiff SWAILS’ pressing of his subordinate’s sexual harassment complaint against Plaintiff P BROOKER’s direct supervisor: Defendant OGLE.

2) LIBEL/SLANDER/DEFAMATION

The Defendants slandered the Careers, reputations, and good names of the Plaintiffs, intentionally placing them in a false light as an excuse for their improper conduct and personal agendas, and because of the actions by Plaintiffs SWAILS and T BROOKER, who were whistle blowers concerning Defendants’ egregious, immoral and conspiratorial conduct.

3) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS/OUTRAGE

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 Plaintiffs, beyond that which a reasonable person could be expected to endure. In point offset, Plaintiff P BROOKER was hospitalized in July of 2007 as a direct result of the actions of the Defendants.

4) LIBEL/SLANDER/DEFAMATION PER SE

On more than one occasion, Defendant ROBERTS has libeled and slandered the Plaintiffs, accusing them of criminal conduct such as extortion. These willful and wanton statements by ROBERTS were intentionally made to damage the Plaintiffs, ruin their reputations and constitute libel, slander, and defamation per se. On more than one occasion, Defendant OGLE has directly-or through surrogates and subordinates-willfully, maliciously, and falsely accused Plaintiff T BROOKER and Plaintiff P BROOKER of having been convicted of criminal activity allegedly associated with a “land swindle in Arkansas.” These untruthful allegations of criminality, made by Defendant ROBERTS and Defendant OGLE, have caused the Plaintiffs to suffer additional emotional distress, embarrassment, and damages.

5) NEGLIGENCE

THE BOARD has exhibited a consistent pattern of negligence regarding its fiduciary and oversight duties to authorize and supervise the conduct of the other Defendants. An example was cited previously in the treatment of a young, female professor at ORU, who had the courage to report instances of sexual harassment, and was summarily constructively discharged. A second example of supervisory neglect also occurred during the Summer of 2007. The BOARD allowed ROBERTS and ORU to give a convicted sexual deviant unrestricted access to the students of the university. Prior to his association with ORU, this man had confessed to crimes within the Court Systems of the City of Tulsa, Tulsa County, and Payne County. All three allegations of sexually-deviant conduct resulted in convictions. In one of these convictions, this “Mentor” for ORU Students-reportedly hired at the direct personal instruction, and under the direct supervision of President Richard Roberts—confessed to the facts regarding exposing himself to a fifteen year old boy in a school locker room. This further demonstrates the BOARD’S wanton and arrogant disregard for the safety of the students under its care, in that, a convicted sexual predator was offered unlimited and direct contact with countless innocent students through the failure of the BOARD to hold accountable the administrators under its authority.
Another example of negligence in oversight occurred exactly three days after this litigation was filed. The BOARD continued its ongoing neglect of its fiduciary obligations by allowing Defendant ORU and Defendant ROBERTS to terminate ORU’S Financial Comptroller—who had 26 years of service to the institution. Within hours of this loyal employee’s unceremonious removal from his office, witnesses have reported that voluminous materials and documents were shredded and destroyed, constituting spoilation of evidence. This reported shredding of evidence represents a continued effort by The BOARD, GRU, and ROBERTS, to cover up their continued, willful, wanton and despicable conduct
Thereafter, according to ROBERTS’ own acknowledgment on national television, a meeting was convened of The BOARD. During this meeting—again, on national television-ROBERTS clearly stated that The BOARD had “heavily scrutinize(d) everything” and offered ROBERTS a vote of confidence, full support, and tacit approval to ROBERTS and ORU for all of their conduct to date.

6) CIVIL CONSPIRACY

The Defendants conspired to violate the rights of the Plaintiffs during covert and unauthorized formal and informal meetings and conversations. At least one of these unlawful meetings-involving three ORU Vice Presidents, was held aboard a corporate jet [Specifically, this jet was a Hawker Siddeley HS. 125 Series 700k serial number NA0256, N455BK. This jet was leased in 2003 for a period of five years at a cost of$l,809,I 85.00 from Tulsa Jet Management, Inc. The lease was signed by Tulsa Jet’s President: William L. Christiansen; and by the Vice President of Finance and Assistant Corporate Secretary of the Oral Roberts Evangelistic Association: David I. Ellsworth. This is the same jet referenced in “Exhibit A”]
During the unlawful meeting on the ORU/OREA jet, the Defendants and other officers of the corporation ORU, conspired to discharge the Plaintiffs. Subsequently, the Defendants, and other officers of ORU, carried out their conspiracy to discharge the Plain~s)-against the advice of their own legal counsel They then instituted a smear campaign against the Plaintiffs to insulate themselves from exposure, liability, or the consequences of their egregious conduct.

IV.
REQUEST FOR RELIEF

The Plaintiffs, and each of them, seek Actual Damages in excess of $10,000, Punitive Damages in excess of $10,000, Attorneys Fees, Court Costs, Prejudgement Interest and any further relief that the Court deems just and equitable.

ATTORNEY LIEN CLAIMED
JURY TRIAL DEMANDED

Respectfully submitted,

Gary L Richardson, OBA #7547
Paul T. Boudreaux, OBA #990
Charles L. Richardson, OBA #13388
6450 5. Lewis, Suite 300
Tulsa, Oklahoma 74136
Telephone: 918/492-7674
Telefax: 918/493-1925

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing was deposited in the United States mail, postage prepaid, this 12th day of October, 2007, to the following:

Oral Roberts University
do Jack Santee, Attorney at Law
401 S Boston Aye, Suite 1100
Tulsa, Oklahoma 74103

Dr. Richard Roberts, President
Oral Roberts University
7777 South Lewis
Tulsa, Oklahoma 74174

Dr.. Wendy Shirk, Dean of Arts
Oral Roberts University
7777 South Lewis
Tulsa, Oklahoma 74174

The Board of Regents of ORU
c/u Rev. George Pearsons, President
14355 Morris-Dido Road
Newark, Texas 76071

Dr. Mark Lewandowski, Provost
Oral Roberts University
7777 South Lewis
Tulsa, Oklahoma 74174

Dr. Jeff Ogle, Associate Provost
Oral Roberts University
7777 South Lewis
Tulsa, Oklahoma 74174

(signed)
Paul T. Boudreaux

stamp(EXHIBIT A)

Scandal Vulnerability Assessment Oral Roberts University, Oral Roberts Ministries Original Draft Prepared by Stephanie Cantese

Investigation of potential areas of legal and/or financial issues in the university and ministry have yielded the following areas of potential vulnerability:

• As of 2003, Richard Roberts was compensated at the following levels—$18 1,469.00 in annual salary from ORU; in excess of $100,000 as Vice-president of City Plex; and an additional $41,530/year from the Oral Roberts Evangelistic Association. Additional incomes ‘from “Make Your Day Count” could not be verified but are likely.
• According to the Draft report, Richard Roberts stated in a taped phone call, “I have the deck stacked—I am elected to three year terms and if a Regent appears to give me trouble, I remove him. I stack the deck….” (Draft report cites a numbered tape as documentation.)
• Richard Roberts receives complete housing benefits from the university which includes all associated costs: e.g. 13 internet/cable connections, wide-screen televisions, hot tubs, an Imperial Stove ($15,000), Washer/Dryers ($6,000), and all furnishings. The family selects furnishings for the home, the ministiy then pays for the items and arranges for delivery.
• The Roberts home has been remodeled 11 times in the last 14 years. Each time, Mrs. Roberts demands more changes. During the most recent renovation, an $800 bathtub was installed for daughter Chloe.
• Dead bolt locks were installed on all bedroom doors at the insistence of the Roberts’ oldest daughter. This was precipitated by Mrs. Roberts repeatedly moving into the home her 16 year old male “friend,” which made her daughters uncomfortable.
• Photos exist of Mrs. Roberts and an underage male smoking at the President’s residence. (Draft report references front and rear photos of Richard Roberts residence with Mrs. Roberts and the young male smoking.)
• Richard Roberts sought approval from stakeholders for moving the underage male into the family residence. With regard to the 16
• Mrs. Roberts has personally spent the night in the ORU guest house with an underage male on nine separate occasions. (Draft report references photos of these events as well as logs from security.) It is reported that this underage individual was allowed to stay in the university guest house unsupervised on numerous occasions. AU living expenses for this individual were born by ORU/ORM—despite reported compliance prohibitions.
• Draft report references 29 distinct photos of Mrs. Roberts and an
underage male alone in her sports car. Time stamps on the photos indicate that they were photographed after the citywide 10p.m. curfew for minors not with their parents. In fact, all 29 photos were taken after midnight. The Draft report cites blog entries from current students confirming these meetings.
•: Draft report cites statements by Victory Christian Students and past employees of VCS confirming Mrs. Roberts presence at the school in the presence of the underage male companion. Security.
tapes showed 81 visits to VCS by Mrs. Roberts and the underage
male to the campus in 2004 alone.
• A longtime maintenance employee was summarily fired so that this same underage male companion could have his position. (Draft report cites a statement from current employee in confirmation of this assertion.)
• At ORUEF, Security removed three individuals for being intoxicated. Photos of the three show that one of the individuals was Mrs. Roberts “boy friend.” She ordered that Security ignore the infraction. (Draft report indicates existence of photos of Mrs. Roberts ordering Security to ignore the drunken youth.)
• Richard Roberts ordered university employees to post a personal message for his daughter on the Mabee Center electronic marquee which read, “Matt, I’m sorry. Love, Chloe.” Mrs. Roberts call an unspecified vice-president at 3:00 a.m. to demand the message be posted. (Draft report cites phone logs which show a total of seven demand calls being made to the same vice-president that morning. Further, a dated and time-stamped copy of written orders from the same vice-president to Mabee Center employees mandating that “Matt, I’m sorry, Love, Chloe” be immediately placed on the marquee.
• A total of 32 complaints were received from employees/public regarding the personal message placed on the Mabee Center marquee. The Roberts were warned of the legal implications of retaliation against employees expressing disapproval. (Draft report cites copies of phone records.)
• Tapes were produced of Chloe Roberts vandalizing and illegally removing athletic department equipment from university property. When confronted with the incriminating tape, Richard Roberts refused to address the issue. Roberts personally benefited from the property stolen, and the damage from the vandalization was billed to the university. (Draft report references the departmental video tape, two witnesses, and a statement from one of the other students involved.)
• University property—specifically golf carts—sustained, serious damage at the hands of the Roberts children. Damages caused by the daughters was billed to the university.
• During Thanksgiving break, Mrs. Roberts repeatedly demanded searches of the Girls’ Dorms for illicit male visitors. Male studenis felt “set up” as their names were released. (Draft report indicates existence of signed affidavits by male students of university persecution.)
• Dormitories were modified for Roberts daughters exclusive use, and all costs passed on to the university.
• Mrs. Roberts provided a key to City Plex Towers, and authorized underaged students removal of furnishings from the Tower to private student apartments off campus.
• Richard Roberts’ 2,000 square foot home office was iemodeled into a walk-in closet to accommodate the needs of Mrs. Roberts wardrobe. This wardrobe has been paid for by the television production cost center.
• Receipts for clothing are routinely handed to ORU/OREA staffers with orders to “cover the charges.” (Original draft notes an attached document reflecting $51,206.00 in clothing receipts) Staffers are under standing orders to modify records/cover purchases to make personal purchases appear to be business related.
• Richard Roberts’ current—and previous—personal vehicles were donated for University/Ministry use. No one outside the Roberts family every used these vehicles. These vehicles are regularly washed, waxed, and cleaned by university employees. Further, all fuel is provided by the university at no charge to the president.
• Both Mrs. Roberts’ white Lexus SUV and her red Mercedes convertible are provided by ministry donors—including all insurance costs. The Mercedes was located online at a dealership in Atlanta. At the explicit direction of Richard Roberts, Ministry Security was flown to Atlanta to take possession of the vehicle and drive it back to Tulsa. (Original draft notes an attachment indicating the ministry department which paid for the plane ticket.)
• Automobiles driven by Mrs. Roberts and the families’ daughters are routinely washed, waxed, cleaned and fueled by university personnel. Richard Roberts makes token payment for compliance purposes.
• The University/Ministry pays for all the families’ home and cell phone without limits. (Original draft notes receipts in excess of $7,000 for phone expenses not including overseas cell expenses.)
• Cell phone bills for Mrs. Roberts and her daughters consistently run over $800/month—with an average of over 1,000 text messages per month. (Original draft notes names of numbers of recipients of calls and texts.) Mrs. Roberts phone records indicate a large number of text messages sent between 1 a.m. and 3 a.m. Two underage males—one of whom Mrs. Roberts was seen alone with after I a.m on 29 separate occasions. This evidence was posted on a student weblog and referenced in the original draft of this report. It should be noted that Tulsa has a 10:00 pm curfew for underage persons not in the company of their parents.
• Records indicate that Mrs. Roberts replaced 21 cell phones in a two year period. Fifteen of her bills during that period exceeded $800/month. Four months had text messages in excess of 800— many of those texts from Mrs. Roberts were sent to underage males—often between I a.m. and 3 a.m.—’who had been provided phones at university expense.
• Draft report documents that university employees were required to express mail “daily care packages” to underage male at retreat in Missouri. (Statements from former employees is cited as supporting documentation.) One of these “care packages” contained a new cell phone which was billed to Mrs. Roberts account.
• Richard Roberts asked stakeholders to permit Mrs. Roberts male friend to reside in their home when questions arose concerning his use of the guest house.
• The university provides and stocks a commercial soda machine in the garage of the Roberts home—with all expenses being borne by the university.
• Meals are routinely prepared by a professional chef, compensated through the television cost center, and delivered to the house for “testing.” Roberts make token payment to satisfy dictates of compliance.
• University and Ministry employees are regularly summoned to the Roberts’ home to do the daughters’ homework (Original draft notes security records, photos and statements to support this contention.) The daughters take the homework completed by the employees, copy the work, and submit it to Victory Christian School as their own work. (Original draft refers to a transcript of a phone call where Mrs. Roberts personally arranges for employees to assist the daughters with homework.)
• The Roberts’ daughters were “home schooled.” Their teacher was on the ORM payroll for over five years. Classes were held in ORU/ORM property which had been classified as a “guest house” for IRS purposes. (According to the Draft report, the property had been fully converted to a school house as verified by photos of the property.) Although no guests ever stayed in the home, all expenses for operation and maintenance were borne by the university.
• The university owns an airplane which is currently used for mostly personal purposes.
• Richard Roberts maintains complete, total control of the university’s airplane and who becomes a passenger on the plane. No other vice-president or regent has any access to this university asset. In fact, individuals have asked to rent the plane—fully reimbursing ORU for costs—and have consistently been refused.
• There are numerous examples of commercial airline tickets being purchased despite space being available on the private jet going to the same destination. Mr. Roberts is highly selective about who he allows on the plane. Space is especially limited if family friends happen to be passengers—personal passengers always take precedence over ORU/ORM employees.
• The university jet was used to take one daughter—with several of her friends—on a Senior Trip to Orlando, Florida, and the Bahamas. The Bahamas portion of the trip was spent at the luxurious Atlantis hotel and resort. This trip was billed to the Ministry as an “Evangelistic function of the President.” (Original draft notes lodging bills from Orlando which included charges for liquor and supplemented with a signed statement from one of the students on the trip.) Photos of the trip show the plane to be full of non-ministry students, and the parents of the other students were reportedly told that this was the daughter’s “senior trip.” The university was billed $29,411.00 for the costs of this “senior trip.”
• During this same trip, the Ministry had need to fly Roberts’ pianist for an event at a local church in Orlando. The only ministry employee on the trip had to fly commercial airlines because the University plane was full of guests on “senior trips.”
• When the older daughter graduated, Mrs. Roberts refused to allow her to attend the Victory Christian School Senior Trip. By coincidence, the University plane just happened to be in the same city at the same time as the Victory seniors—allowing the daughter to participate in the Senior Trip but with the costs being borne by the university. Apparently, Richard Roberts will book a speaking engagement in the city the daughters wish to visit and then bill the university for the cost of the trip. (Original draft indicates existence of student statements, copies of retained memorabilia, photos of the plane/trip, and receipts from resorts in the selected cities. Further, original draft notes a van rental receipt on one of these trip in the name of Oral Roberts Ministries.)
• The Roberts flew the ministry plane to Florida on December 26th, staying at the posh Breakers Hotel. (Draft reports cites existence of photos of non-university guests in rooms with meal/room charges paid by ORU/ORM credit cards.) All vehicle rentals were charged to ORU. This was cited as another example of a single speaking event in Florida being used to cover volitional travel for multiple persons. Once again, Mrs. Roberts didn’t even attend the service which justified the travel expenditure.
• Roberts routinely visits his father in Newport Beach, California and bills the costs of the trip to the university. (Original draft included names, dates, photos, costs of vacation villas, and receipts for rental vans/cars—all billed to Oral Roberts University and Oral Roberts Ministries.) On one trip, which lasted fourteen days, Richard Roberts visited Oral only four times, yet billed the entire cost of the trip to the University/Ministry.
• On several speaking engagements in Dallas, Texas, Mrs. Roberts accompanied her husband. In each instance, multiple vehicles were rented by the couple and charged to the University/Ministry. Records indicate that Mrs. Roberts did not attend any of the meetings conducted by Richard Roberts. (Original draft notes several photos showing Mrs. Roberts shopping with numerous guests.) Four photos clearly show Mrs. Roberts with a young, blond male which her own sister referred to as “her boy friend.”)
• Mrs. Roberts routinely has ORM provide her with security personnel as protection while on personal vacations. On one occasion, Mrs. Roberts took one of her daughters and “a male companion” on an overnight trip to Branson. All charges for transportation, lodging and meals were paid by ORU/ORM. (Original draft references receipts for clothing dubbed “TV wardrobe, Branson, Missouri.”)
• According to the Draft report, nine separate statements were collected which quote Mrs. Roberts as saying, “As long as I wear it once on TV, we can charge it off…” Draft notes inconsistencies in expense account between reported TV clothing, and actual TV usage. (Draft cites photos of closets by Chloe’s friends of clothes with tags charged to TV account—cell phone photos were circulating among her friends.)
• Mrs. Roberts spent over $39,000 at one clothing store alone— Chico’s—in less than one year. Employees in the ministry assert that other accounts exist for stores in Texas and California which greatly add to the total.
• Mrs. Roberts ordered that her children be paid $200/song on the television show. One random student was found to pay the same rate, so as to justify the amount paid her children.
• The Roberts daughters are allowed to use Oral Roberts’s home in the compound for a token payment.
• ORU/ORM maintains a stable of horses for the exclusive use of the Roberts children. All costs associated with this stable are borne by the university.
• ORU/ORM Security personnel are routinely used by the family to fetch groceries, hair bows and accessories, family meals, and even undergarments for the girls—all while on the university payroll.
• Mrs. Roberts personally awarded thirteen non-academic, non need-based scholarships exclusively to friends of her children. Two of the recipients scored 12’s on the ACT, making them academically ineligible for admission to the university. When informed that the two students with 12’s on the ACT could be admitted contingently and put into the Bridge program, Mrs. Roberts demanded that they be admitted without condition and that the questioning employee be fired. (Original draft references affidavit and copies of all transcripts of students awarded scholarships. Additionally, copies. of awards for full room, board, and tuition scholarships, bearing Mrs. Roberts signature, were attached.)
• Mrs. Roberts was informed that these unilateral scholarship awards might constitute enurement, as she often received significant “thank you” gifts from the recipients or their parents. The unfortunate aspect of these scholarship awards to questionable students was the depletion of limited resources to fund the
educations of more worthy candidates.
• After awarding the thirteen full academic scholarships to friends of the family, Mrs. Roberts established the “Make Your Day” scholarship. This financial aid was advertised as serving needy students. As before, Mrs. Roberts selected the recipients from a pool of mostly friends of the family.

President Roberts is paid from following pay sources
OREO $41,530
OUR $181,469

Benefits
All housing costs are pained including 13 internet cable connections in home
All house furnishing are paid — he /she finds selects ministry obtains pays and delivers Including wide screen televisions, hot tubs, imperial stove ($15,000) washer/dryer $3,000 each
Home has been remodeled 11 times in 14 years and every time Mrs. Roberts demands changes — recent $800 bath tub for daughter Chloe
Dead bolt locks this summer were placed on all bedrooms due to demands of older daughter when Mrs. Roberts’s male 16-year friend was moved in repeatedly to live in presidents home
Mr. Roberts home office has been remolded 2,000 square feet to accommodate Mrs. Roberts wardrobe- paid for by television production —receipts are constantly handed to staff and told to cover such- current bills for clothing charged as wardrobe by Mrs. Roberts in excess of $51,206.00 (documents attached) staff has been instructed to alter and cover to make it work for compliance
Mr. Roberts’s auto is cleaned washed waxed and all gas paid by university/ministry Vehicle is donate to Ministry University for usage
Prior ministry van donated by partner was used exclusively by Roberts and family same with SUV vehicles
Mrs. Roberts Lexus SUV white was donated given to her - insurance paid by donors partner
Mrs. Roberts red Mercedes convertible was paid for by partner and Roberts
Orm security flew to althan after searching for president for vehicle procuring it on internet and then staff sent to Atlanta (check documents for trip records and department charged fro plane ticket) employee drove vehicle back to orm campus per president’s instructions
All phone bills home and cellular are paid in frill no limit see records in excess of $7,000.
For cellular- oversees cell charges have been omitted)
A commercial soda machine in garage is filled by orm employees and billed to university Meals by television paid chef are delivered to house for testing (president pays token charge to satisfy compliance)
University employees and ministry are routinely called to presidents home to do daughters home work (see security records, photos and statements) daughter then takes answers copies in own handwriting and submits to victory Christian school as own work Mrs. Roberts selects employees to perform homework assignments- see transcripts of taped voice mail messages
President Roberts uses ministry jet to take daughter friends on senor trip- to Orlando Florida and Bahamas - recent stay was at Atlantic resort - billed to minacity as evangelistic function of president- note copies of bills for lording in orland include liquor charges -note signed statement of student on trip- students and partents told this was his daughters senior trip- students pictures attached show airplane full with non ministry students- when Roberts pianist neded to come to I time event to play in orland church she had to fly commercial- charged to ministry as plane was full with non ministry guests of daughter- resident explained it was less costly for her to come in middle of trip — check records cost of plane trip and hotel costs- far less than costs charged to ministry All students on plane were guests —on non ministry trip
President charged all costs in excess of $29,411.00 to university
Same for older daughter- dates conveniently coninevcide with daughters victory Christian senior trip wheihc mrs Roberts refused to allow daughter to participate in - Roberts exchange find churchs in area where girls desire to go for trip and book preaching- see students statements and copies of retained memorbeia — see photos of plane, trip, resort and receipts
Note name of auto rental van — arm
Roberts consistently takes vacations in Newport beach to bvisti chancIer- note names attached to photos and costs of vacation villas- vehicles vans rented in names of orm and uivneritsty paid for wehicles gas and usage- present per records obtained from condominium complex show president and chancellors assistant paid thorugh oru payroll chancellor visited 4 times during 14 day lodging travel van billing
On every speaking event Roberts attents in dallas where wife accopmpanies 2 vehicles are rented and charged to university- photos show mrs Roberts shopping with numerous guests and did not attend any speaking preaching events- see 5 times dates of rental receipts and photos of mrs- (note male blond is mrs Roberts boy friend -004 occassions)
Mrs zvbetrs charges orm for security to follow her on personal vacations with daughter and male companion to Branson see documents and photos all lodging meals and costs charged to orm am- note shopping receipts for tv wardrobe branson missiour, grapevine texas, 17 californina, note dates coincide with preaching trips charged to ministy

Mrs Roberts vehicles cleaned gased waxed and maintence charge to university Daughter cvheicles cleaned gassed waxed and maintence charged to university Vice presidents assess nominal fee to meet compliance standards —13 non acadmenic nom financial need scholarships given by mrs Roberts exclusibvely without any outside oversight or input- all friends of hers children or daughter male Mends -2 students had 1200 act - making them ineliglible for admissions when mrs Roberts told they do not meet standards and bridge status offered she demand full ride no exceptions individual who questioned standard terminated -see avidavit and copy of all transcripts of students given full tuition room and board scholarship and signature per mrs Roberts—told this violates enureinent as mrs Roberts hand picks students and often times receives “thank you” gifts for her generousity.
Directly impacts students eleiglable for supporsidly adversited scholarships based on academic standards and finalcial need
Her make your day scholarship fund established when president cut scholarship budget deu to her wanton handing out of scholarship this penalized deserving students dramatically — her make your day scholarship is adveristyed as open to needy student —schoarlshipship recipients are hand picked (see names and statements) and mrs Roberts is anluy authority- note names of receiptients- majority again are mrs Roberts childrens releavies and her male Mends)

Mr Roberts has total contraol of uiversity airplane and guests No other vp director or board member has such authority
Others have requestred and offrer to do so agreeing to fully reimburse ministry —refused Commercial airline tickests are repealtlyedly purchased even though space exists on private ministry aircraft president is very selvective who he allows on airplane with him Espwdcially if he is bringing daughters Mends or wifes Mends - they always take preceident
Daughters and mrs Roberts cell phone billh have exceeded $800 repeatedly Mrs Roberts and daughter have text message averaging over 1,000 messages per month
See records- note phome number and name of user — number of messages and times — the
repeatedly 1-3 am calls are to the 2 under age males seen in the attached photos and the 1 in the male mrs Roberts is see in the web blog with 29 times after I aam — alone —although Tulsahas a 10pm curfew for children not with their parents­Mrs Roberts has personally stayed with young male in am orm guest house on9 occassions see photos and log- compliance specifically forbids yet mrs Roberts and see photo mr Roberts have brought this non ministey individual and permitted him to live in these guest houmes repeatedly- providing foold uititiyes and all housekkping (charge to minisity)
mr roberts demanded minisity personle put up mabee center markee — matt hit sorry love chloe- on mabee center marquee- see photo of marquee and message- see attached phone log mrs Roberts called vp at 3 am with demand to put message on markee —ssee presidents phone log —6 vcalls to same vp same day with demand) note copy of vp;s messge to employee to put mats in sorry 00mb center marqee and time of such-

32 calls were made to voice complaints of such message on marquee — see copyh of records — empplyee statement and employee have been requestred with legal counsel and federal whistle blower act would be insued if any action is taken against employee)

Traco?
Eagle Broadcasting
8181 Management

Compensation
Orea evangelistic association 41,683
City plex Vp 100,000+
oru
Make your day count
What other sources of income

Rr2003
Orea 41,500
Oru 181,469,
What other sources of income

Morality

Enurement

Chloe- tapes exist of her vandalizing athletic department and taking equiptment- when confronted with tape rr — refused to address He personally gained from materials stolen and damage was not repaid — source document copy of video tape —2 witnessess — student involved in incdent statement

Damage to equiptment
University ministry owned golf carts signifigantly damaged by rr’s children — he charged costs to university ministry to repair damage to vehicle and property ministry damaged by children- and guests

Childrens home school teacher paid from oem payroll for 5+ years
Classes held in uinverysity ministry property termed for irs purposes as guest house — proverty converted to school house see photos
No guests stayed in property all expenses related cleaning heating charged to university

Assets — universyt owuen and currently leased airplane used for personal pureposes
Lmichaeljordan sports event- see copies of documents filed —photos —statement affidavit

Senior trip for daughters- see photos copy of receipts atlantis hotle resort Bahamas- photos names of stuents on plane — statemebent by student guest purpose of trip events
See hotel receipt — liquor charges —
When lean norm employee flew down to play for rr she had to travel commercial — charge incurd by ministry
All seats except rr’s on airplane occupied by non ministry friends of president and family
See copy of flyer attached- date of church meeting in flordia and bahama see download from internet site- note date of meeting note hotel date(S) costs charges
See same for 2002 — JR same locations — concidence- statement attached from participant and parent — see copy of receipt obtained from lodging establishiment and record in interal file from former employee as to classffication of event to “qualify for reimbursement”

Mabee center signage- see attached photo- matt I am sorry love chloe See copy of phone log showing Ir’s call @3:00 am and 6 x RR prior to 6 am to vp dempaning signage virbage
30 x calls to orm/oru regarding message and personal usage of assets

Newport beach- see charges — note names on log for airplane and omission of names
Note cost for facility and dates — inconsistent with meeting excess X 2
Breakers hotel- dec 26th - note hotel note photos of non university guests in room(s) meal charges on university ministry credit cards
Vehicle rentals qunaity unver name of university — only person speanking what rr- note consistency of booking of 1 day 1 speaking event with travel to florida- per church ms robei-trs did not attend see photo

Use of personal for personal

Security used to fetch groceries, hair bows, called randomly to go to pick up famiiy meals, girls undergarments, hari accessories all while on orm ore payroll

Use of guest house for mrs Roberts male friend- consistently house used by 15,16,17 male guest of ms Roberts- see log and photos
Has no relation to usage or need of guest house- orm staff cleans home all uititiey services bore by minisity on’ for her guest personal use of numerous guest houses — secheduled guests relocated moved elsewhere cost charged to orm for relocation

Secrity to travel behind mrs Roberts for trips with male to branson and such- see photos
Cost for orm employee to floilw ms Roberts on personal trips use of ministry vehicle by employee and all costs associated with such room board and such —4 x see records attached

Phone- replacement of 21 phones by lr in 2 year peiord
15 celluar bills in excess of $800 per month
4 with text messages in excess of 800
Consist number to 2— under age males note times of 1 am , 2 am 3 am Numbers check out to ______ names omitted due to age details are filed elsewhere
Mrs Roberts has aquired celluar telephone for same invidivual
Note copies of express mailing from mail room to invidual at campe retreat in missiour former emplouees documents mrs Roberts requirements to send care packages daily to invidivual
Orm paid for mailing of said packages and new celluar telephone charged on ms Roberts account

Copies of documents with ms Roberts and underage male male is smoking at presidents home see front and rear photos of president prooetty with ms Roberts and male smoking
29 attached photos of ms Roberts and male alone in her sports car note times stamped on photos after city wide curfew for minors- 10 pm — all are after 12 p.m. midnight
Note statements attached on blog site by current stiuents

Statement by yes students and past employees regarding ms Roberts presentce at school iwht male student per staff—tape shows SI un 2004 school year

Firing of long time maintenance employee to create position for same individual- statement attchaed by current employee

12 names attached are names of students given scholdarships by ms
Roberts personally with samid calls made to department
2 students had 12 on act- making ineligible for admission- ,ms Roberts demanded full admission and scholarship- note every name is friend of Roberts children —
Note letter of concern expressed regarding favoritism of students given scholdarship creating less scholarships for qualified students as represented in student materials and to partners and viewers
Note success of sutents and nuermical averages qreatly requceted when these students are admitted thus rndcing potential to recuit quality students

Oruef — note names of individuals removed by security for being intoxicated 3 indivudla is same indivula ms Roberts is seen with in above photos and note her demand to igonor him

Thanksgiving- repeated demands by ms Roberts to seach girls dorms due to concern that males wuld be in dorms and when found wohuld give name as male abbe to set him up — see signed affidavit — costs to be determined upon investigation

Dormitory modifications for Jr onlyu and friend- enurment cost incurred byoru—
Use of city pies furniture for ma Roberts personal friends she provided key to faicity and approvied taking furniture off campus to students homes apartments
Clothing —9 signed statements by inviduvals stateing ms Roberts-. as long as I wear it 1 time on tv we can charge it off
Statmetns to jr see documents
Expense account inconsistent with usage of tv clothing
See documents
See photo of clothing closet with tags by does “friends” photos was circulating on celluar phones downloard —

See chico’s bills see all receipts for ms Roberts tv clothing expenses, see haior expense account , see eye glass charges , shoes — in excess of $39, 000 for less than 1 year — more documents exist this was all employee was able to obtain in that afternoon-
Has provided names of additional clothing stores in californa and texas

Mrs Roberts car obtained in Atlanta — see charged airline ticket by orm employee to personally fly up and obtain car — see documents submitted for reimbursenet for trip expenses mrs borterts personal car
See all travel records for personal trips vehicles rented quanity 2 vans-even when church offers to provide transportation to rr- for 1 person 1 vheicle — he charges 2 vheicles consisteinty to orm

Gas for childrens car personally paid by minisitery — asked to put token amount back for audit purposes-
No other signer receives clothing allowance — gas or vehicle allowance or any of the perks
Fall break $200 to sing 1 time on show- per lr demand
Found noather student to perfor and paid same to justify for compliance
Scholarship reads 1 year- not exception is made for any time off or extra compensation

Chanclers house- token paid for use by daughter and 2 friends
Trips taken by dauthers friends with unrelated job description to concide with sightseeing and such all costs paid by orm

Assets horses- miistry donation of aminal- only rr daughters ride animal orm pays all costs associated

Celluar telephoonse and equiptment by orm — token paid back Choles bill — see copies of time text message )content of works, note Ira responses and messages on hers)

Use of orm oru employees to do daughters homework
Employuees required to come to house or pool and do choloes homework and tests — consistently security tape of empplyees coming to house — photos by friends of girls show doing her homework- see 3 enlarged celluar photos — chole then copies in her handwriting and turns in as her own

Drinikg —pres Roberts asked others to permit ms Roberts male frined to -reside with them when fearful compliance whou question him using guest house- taped phone call — I have deck stacked — I am elected to 3 year terms and if a regents appears to give me trouble I remove him-I stack the deck- see tape number 7
Then asked same person to allow mrs Roberts male friend to live with her and permit facility his drinking and smoking “we were all kids” comment he is only 16— we let him smoke her- just tell him to go outside by the pool no one will know”
Tape 18 ms Roberts we love him so I am so jealus of you I want him to live with me- hie has been physically and emotionally abused and iso love him- same name in tape of abusive mother is same women who is repeatledy on ms Roberts dailty tv show make your day count —teaching how to raise godly children

Ncaa- mrs Roberts has althelets on tv show see tape 29
And gives them gift baskets of gifts and gift certificates
See copies of log of guest and gift certificates
Ncaa violation

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