District Court, Tulsa County, State of Oklahoma

“ 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. ”

“ 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. ”

“ Roberts is highly selective about who he allows on the place. 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.” ”

“ 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, LEWANDOWSKI impounded SWAILS’ office, needlessly directed two Security Guards to public 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. ”

“ This edict from ROBERTS’ on behalf of ORU, as President of the Corporation, wherein 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 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 other contracting campaign. ”

“ The Plaintiffs were employed pursuant to various written and oral contracts with ORU. However, the Defendant, ORU, breaches 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. ”

“ 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 were Mrs. Roberts personally arranges for employees to assist the daughters with homework.) The Roberts’ daughters were “home schooled.” ”

“ 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 report 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 for a single speaking event in Florida being used to cover volitional travel for multiple persons. ”