JOE DELGATTO, et al                                           
DEFENDANTS                                                      §  280th DISTRICT COURT

TO THE HONORABLE JUDGE OF THIS COURT

COMES NOW, Plaintiff, Joyce Wolter, and files the above MOTION FOR SHOW CAUSE HEARING and would show the court the following.

The Defendants have stolen and conspired to steal money from Heights Presbyterian Church and have attempted to cover up their theft and other acts of fraud and conversion.

Attached as Exhibit “A” is a summary of the WorldPeace Disbarment which Reagan Brown has thrown into this lawsuit as a red herring to distract the court from the undeniable corrupt acts of the Presbytery of New Covenant whose bad acts he is attempting to defend.

WorldPeace would show the court that on February 10, 2003, at a hearing in this court, the court simply denied WorldPeace's motions in order to allow the Administrative Commission to have some time to work. WorldPeace would show the court that the Administrative Commission was only appointed two days prior on February 8, 2003, in response to the hearing that was to take place in this court on February 10, 2003.

WorldPeace would show the court that contrary to the Book of Order of the Presbyterian Church, the Administrative Commission was formed when only eight of the twelve members of the Heights Presbyterian Church session went to Presbytery along with Joe Delgatto, the rouge minister of the church, in order to have the Administrative Commission appointed. Delgatto and the other members of the session did not inform the four members of the session who are fighting the corruption at Heights Presbyterian Church that they were going to Presbytery. The Administrative Commission was formed illegally and against the rules per the Book of Order in that it was formed without talking with all the session members.

WorldPeace would show the court that this is just one of many incidents where the Presbytery of New Covenant selectively enforces the rules of the Book of Order in its attempt to cover up the bad acts of Delgatto.

WorldPeace would show the court that as he expected, there has been no communications of any real substance between the Administrative Commission and the congregation. WorldPeace would show the court that there has not been a single open congregational meeting in four months.

WorldPeace would show the court that the only meeting between the members of the congregation were meetings that were set up by the Administrative Commission in which individuals of the congregation were allowed no more than ten minutes to speak to members of the Administrative Commission. If a husband and wife attended the meeting together, they were limited to ten minutes. Only if they agreed to meet separately would they get two meetings of ten minutes as opposed to one.

WorldPeace would show the court that during this one and only meeting with the rank and file members of the congregation in the last four months, thirty-five members handed to the Administrative Commission accusations and complaints against Joe Delgatto. Neither the Administrative Commission nor Presbytery of New Covenant has responded to a single one of those accusations and complaints that were turned in per the Book of Order.

WorldPeace would show the court that the individual members of the congregation were told that those accusations and complaints against the minister would be handed over to the Presbytery of New Covenant, which appointed the Administrative Commission, and the Presbytery of New Covenant would per the Book of Order look into those allegations. This has not happened.

WorldPeace would show the court that no committee was formed to investigate those thirty-five complaints, which were each six pages long. No committee has been established to look into those complaints. Nothing has been done.

Consequently, there has been no communication from the Administrative Commission to the congregation except to listen to short ten-minute statements by the members of the congregation, which as this court knows is a very limited amount of time. However, each member did write down and deliver their full range of complaints to the Administrative Commission, none of which have been investigated.

WorldPeace would show the court that prior to February 10, 2003, in December 2002, Plaintiff did file an accusation with the Stated Clerk of the Presbytery of New Covenant. WorldPeace would show that that accusation was refiled in February 2003, when Plaintiff met with the Administrative Commission and nothing has been done. Plaintiff also filed an accusation against the preachers wife, Madeline Delgatto, and Patty Ellis for the disparagement of Plaintiff's good name by saying that she was living with Vernon LeCompte. WorldPeace would show the court that nothing has been done on that accusation either other than a short meeting between Plaintiff and two individuals from Presbytery.

WorldPeace would further show the court that Patty Ellis and her husband Walter Ellis came to Heights Presbyterian Church about two and a half years ago from Saint Philip Presbyterian Church. Saint Philip Presbyterian Church allegedly asked the Ellis's to leave the church because of Patty Ellis’s psychotic behavior and her obnoxious acts toward virtually everyone in the congregation. Ellis’s behavior has continued on at Heights Presbyterian Church.

The first attorney hired by the Heights Presbyterian Church session to represent Delgatto was Diane Fieler McGehee. (No contract has been produced by Diane Fieler McGehee. Ms. McGehee was also a member of Saint Philip Presbyterian Church and her husband was the minister there at one time until he had an affair and eventually ran off with one of the members of the congregation).

Further, WorldPeace would show the court that one member of the Administrative Commission is an individual who is also from Saint Philip Presbyterian Church. In addition, one of the two people who are included in the investigation of the accusation by Plaintiff against the preacher’s wife and Patty Ellis is also from Saint Philip Presbyterian Church.

WorldPeace would show the court that the Presbytery of New Covenant has one hundred and one churches under its jurisdiction and yet it seems that in every aspect of this corruption Saint Philip Presbyterian Church is represented.

WorldPeace would show the court that Plaintiff filed two accusations. One accusation was against the preachers’ wife and Patty Ellis; the second was against the preacher. No investigation has been made of the preacher.

WorldPeace would also show the court that in February 2003, thirty-five complaints were filed against the preacher and not a single one of those complaints have been investigated by the Administrative Commission. Nor, has an investigatory hearing been set up by Presbytery to look into those allegations.

WorldPeace would show the court that on May 8, 2003, the Presbytery of New Covenant met in its quarterly meeting and refused to set up an investigative committee to look into the bad faith acts of Joe Delgatto as alleged by thirty-five members of the congregation.

The Administrative Commission has already said that they will not look into the accusations that were turned over to them in the ten-minute meetings that they had with the individual congregation members. WorldPeace would show the court that this is very strange in that when Delgatto and his eight rouge session members attended the quarterly meeting of Presbytery unannounced on February 8, 2003, that the Administrative Committee was immediately set up and yet three months after these thirty-five allegations against the preacher have been filed not a single thing has been done.

WorldPeace would point out to the court that this is just another example of the corruption that is going on within the Presbytery of New Covenant, where the primary objective is to cover up the embezzlement of monies by the Defendants from Heights Presbyterian Church in the amount of $600,000 in addition to the illegal commitment of Heights Presbyterian Church to the corrupt Independent Heights Project.

WorldPeace would show the court that there have been two Interim Reports sent out by the Administrative Commission. (Exhibit “A” and “C”) Both of which speak only to the Independence Heights Project. Neither reports speaks to the audit of the church finances. They do not speak to any of the thirty-five bad acts of Joe Delgatto nor to any other issue other than the Independence Heights Project.

It is obvious that the Administrative Commission was formed for one and only one reason and that was to push through the Independent Heights Project. There can be no denial that this is what has happened. There has only been one meeting with the entire session, which was on March 24, 2003.

That meeting was an open meeting in which all twelve session members had a total of

thirty minutes to speak. After that, Reagan Brown read the March 24, 2003, Interim Report by the Administrative Commission to this session. (Exhibit “A”)

WorldPeace would also show the court that at the March 24, 2003, meeting Plaintiff, Joyce Wolter, held up the court's injunction of December 6, 2002, saying that the Independent Heights Project was not to be discussed nor was it to be discussed without John WorldPeace present. Reagan Brown and Roy Keezel, both attorneys at law, and Doug Harper, the head of the Administrative Commission, told Plaintiff and the other session members that the court's order was meaningless and void and that they were not required to abide by it.

WorldPeace would show the court that the Book of Order does require that the session, congregation, and Presbytery approve any projects which obligates the church. It is an absolute lie that there is no monetary commitment from Heights Presbyterian Church to the Independence Heights Project. In fact, in April, 2002, Tom Lord wrote a letter in which he specifically stated that the church would have potential financial obligations. Now the Administrative Commission has come in and tried to lie to the congregation and more importantly lie to this court about the financial obligations of Heights Presbyterian Church to the Independence Heights Project.

WorldPeace would also show the court that the Independence Heights Project is proceeding forward regardless of anything that is going on in this lawsuit or any requirements per the Book of Order.

At the groundbreaking on May 25, 2003, just two weeks ago, there was a sign where it specifically stated that Heights Presbyterian Church is a sponsor of the Independence Heights Project. If Heights Presbyterian Church does not need to sponsor the project, then why is Heights Presbyterian Church involved in the Independence Heights Project at all?

The truth is that HUD requires that a non-profit organization sponsor the project. Heights Presbyterian Church is the sponsor of the Independence Heights Project and Heights Presbyterian Church has financial obligations to the project and those obligations will exist for the next forty years.

WorldPeace would show the court that the Administrative Commission has tried to allege that an independent corporation, Independence Heights, Inc., is now solely responsible for the Independence Heights Project. This is an absolute lie. Without Heights Presbyterian Church's sponsorship of the project and the fact that the board members of that Independence Heights, Inc. are members of Heights Presbyterian Church there would be no Independence Heights Project.

WorldPeace would show the court that without Heights Presbyterian Church's participation the Independence Heights Project would fold up. The reason for this is that there must be a non-profit organization sponsoring the Independence Heights Project. That organization must guarantee the financing of that project.

WorldPeace would show the court that Reagan Brown's has knowingly foisted a pack of lies on this court.

In the next section Brown says that Independence Heights, Inc. has no legal relationship to Heights Presbyterian Church. This is an absolute lie. Joe Delgatto, Walter Ellis, and James McClain are all members of Heights Presbyterian Church and they set up Independence Heights Inc. to perpetuate their fraud upon HUD, the congregation and others.

The fact that Heights Presbyterian Church has no financial or legal liability for the Independence Heights Project is nothing but a lie. That is contrary to what Tom Lord said in April 2002, and if it is true then why is Heights Presbyterian Church listed as a sponsor of the Independence Heights Project on the sign in front of the project.

WorldPeace would show the court that not a single affidavit has been attached to Brown’s Status Report because no member of the Presbyterian Church nor Reagan Brown is willing to swear to the lies that are being foisted upon the court in this bogus status report.

WorldPeace would show the court that the Administrative Commission's statement that no evidence has been found that the funds of Heights Presbyterian Church have been funneled into Independence Heights Project is another un-sworn and un-verified lie. Not a single person has stepped forward and made a sworn statement. The reason is that those fundings were done behind Heights Presbyterian Church's back and one particular congregation member, Diane Springer, personally attempted to commit Heights Presbyterian Church to the Independence Heights Project.

WorldPeace would show the court that there is a letter from Dr. Hammond, President of Independence Heights, Inc. that says that the $5,000 from Springer obligated Heights Presbyterian Church to the Independence Heights Project. (Exhibit “E”) I do not know what kind of word games that Reagan Brown is trying to play but the truth is the truth. The money came from Heights Presbyterian Church and the fact that the money actually came from Diane Springer instead of being funneled through Heights Presbyterian Church and then into the Independence Heights Project had the effect per Harmond’s letter of obligating Heights Presbyterian Church to the project.

WorldPeace would show the court that in addition Delgatto signed several documents that have already been entered into evidence that committed the church to funding the earnest money contract to the people that were selling the property upon which the Independence Heights Project is to be built and Delgatto swore in court he had no authority to do this.

WorldPeace would also show the court that the property was bought for $230,000 when it was listed on the tax rolls for $37,000. WorldPeace would like to know whose money Delgatto was committing to the project. Certainly, Delgatto was not committing his own money to these earnest money contracts.

WorldPeace would show the court that there is a question as to where that earnest money actually came from. If it came from Tom Lord, it shows the corruption and the fraud upon HUD because Tom Lord is a profit organization and it is his housing company that is funding the project and not Heights Presbyterian Church.

I can assure the court that when HUD finds out how these commitments were actually financed there will be some indictments coming down from the federal government that will put Tom Lord, Joe Delgatto, and others into prison.

WorldPeace would show the court that the Inspector General is the one who is charged with investigating these HUD matters and when these matters are investigated I can assure the court that there will be some people who will be indicted for their bad acts. This is exactly what the Presbytery of New Covenant is concerned about and this is why the Administrative Commission has been appointed for one and only one reason and that is to push the Independence Heights Project through and cover up the fraud of Delgatto, Lord and the other Defendants.

WorldPeace would show the court that Reagan Brown is putting himself in a very precarious position by signing pleadings that he knows are untruthful.

WorldPeace would show the court that in an attempt to blackmail Joyce Wolter into dropping this lawsuit, five members of the Administrative Commission visited her at her home and threatened her if she did not drop the lawsuit. Wolter did not drop the lawsuit and the reaction was that the Administrative Commission allegedly relieved her as trustee of Heights Presbyterian Church. (Exhibit “F”)

WorldPeace would show the court that it is very interesting when a whistle blower is terminated. There is only one reason that this happened and that is because of the corruption. Regardless, Joyce Wolter, was a trustee during the period of time when these monies were being embezzled by Defendants and when the commitment was made to the Independence Heights Project. Whether Wolter is or is not presently an official trustee of Heights Presbyterian Church is irrelevant. What is relevant is that she was a trustee at the time of the corruption.

Wolter still has standing to sue in this lawsuit because at the time of the corruption, theft, fraud and embezzlement, Wolter was a trustee of Heights Presbyterian Church.

The Administrative Commission and the Defendant’s have insisted, without any motions in this court, that the court's injunction is not valid and that this court has no authority over them even though this court did in fact sign an order. (Exhibit “G”) Brown makes the ridiculous assertion that because they have now tried to terminate Wolter as a trustee, that she has no responsibility for the period in which she was a trustee. I question the legal education of Brown to make such a ridiculous assertion.

WorldPeace would show the court that Plaintiff is talking about theft of funds from Heights Presbyterian Church by Delgatto and others. Therefore, this gives this court jurisdiction. If there is no jurisdiction of the court over pedophile priests then I would agree that there is no jurisdiction of the court over the theft of funds from the church. To say that the since church is operating as a non-profit organization it can set up prostitution rings, pedophile priests, theft, and so forth is absolutely ridiculous.

The non-profit barrier does not include tortious acts or criminal acts by members of the Presbyterian Church any more than tortious and criminal acts by a corporate employee are protected by the corporate shell.

WorldPeace would show the court that the only thing that is going to be acceptable to Plaintiff will be a full blown audit for the past five years while Delgatto has been the minister at Heights Presbyterian Church.

WorldPeace would show the court that a “financial review” is not acceptable and is simply a review of documents that are given to the person conducting the review. A financial review does not account for every dollar. WorldPeace has spent twenty years in the accounting business and is very familiar with what it takes to track down corporate embezzlement. There needs to be an audit with a view to finding criminal and tortuous acts. A financial review will not accomplish this.

The red herring of a “financial review” that Brown has thrown out is totally absurd and ridiculous.

WorldPeace would show the court that the Administrative Commission, the tool of Presbytery of New Covenant, is scared to death that the bad acts of Delgatto are going to come to light.

The court is the only hope for the members of the Heights Presbyterian Church congregation who have been the Defendants’ victims.

WorldPeace would show the court that the appointment of the investigative commissions was something that was done in December 2002, three months prior to the Administrative Commission coming into the picture.

What Brown neglects to tell the court is that there were thirty-five accusations and complaints by the members of Heights Presbyterian Church who when they were allowed their ten minutes in front of the Administrative Commission, handed their accusations to the Administrative Commission. That is thirty-five complaints, all of which were five or six pages long and had a laundry list (See Exhibit "D”) of things that they did not like about what was going on at Heights Presbyterian Church.

None of these complaints have been investigated by the Presbytery, not a single one. There is no investigatory commission set up to investigate and if there was then Brown would have so stated in his Status Memorandum.

Brown has not been completely forthright with the court. There was a meeting of the Presbytery on May 8, 2003, and they did not appoint a commission or a committee to investigate the bad acts of Delgatto.

Again WorldPeace would reiterate that Delgatto and his eight co-conspirators from the Heights Presbyterian Church session went to the Presbytery on February 8, 2003, and that very same day an Administrative Commission was appointed. Now three months after these accusations and complaints have been filed with the Administrative Commission not a single thing has been done. That is because the Administrative Commission was formed for one and only one reason and that was to cover up and ram through the Independence Heights Project. That is the only thing that has been talked about and that is all that has been discussed in the two Interim Reports that have been released.

There has been no open congregational meeting and there has been only one short meeting with all of the members of the session. Nothing has been done by the Administrative Commission except the ramming through of the Independence Heights Project and the intimidation of the members of Heights Presbyterian Church; member like my mother who they have attempted to remove as trustee of Heights Presbyterian Church.

WorldPeace would also show the court that the thirty-five members who have signed these accusations and complaints are the members of the church who have been members for three, four, and five decades.

WorldPeace would show the court that nothing should be stayed at all, if anything there should be a Show Cause Hearing to immediately investigate the Independence Heights Project where all the co-conspirators can come into court and under oath swear to what is going on with the Independence Heights Project.

WorldPeace would assure the court that when this happens the entire Interim Report will reverse itself. WorldPeace alleges that without a court order the Defendant’s will not attend a hearing.

It is the intention of the Administrative Commission to continue a choke hold on Heights Presbyterian Church and to cater to a hand full of members at the expense of the entire congregation of Heights Presbyterian Church as well as try to stay this lawsuit until such time as the Independence Heights Project is complete. This is nothing but an attempt at further corruption and Brown is trying to bring the court into his bad acts and the bad acts of those whom he represents.

WorldPeace would show the court that due to the fact that this matter has been stayed, depositions have not been taken of Delgatto, Lord, Harper, and others. Consequently, a statement by Brown that there is no evidence of any bad acts is absurd.

These are the people who are advocating a financial review. These corrupt people know exactly what they are doing. They know exactly what an audit is going to show. They know that with an audit this entire corrupt matter in regards to theft of the Heights Presbyterian Church funds and the Independence Heights Project will all come into the light and people will go to jail.

WorldPeace would show that there were a lot of things that were sent to the opposing counsel. After the court made its ruling, WorldPeace honored the court's request to stay all proceedings and did so. However, WorldPeace did in a few instances warn, through sending faxes to the other attorneys what his intentions were going to be after the stay was lifted.

WorldPeace would show the court that it is a blatant lie that on February 10, 2003, there was no statement enjoining the Administrative Commission from talking about the Independence Heights Project. There was an injunction in force that was not vacated by the court.

(Exhibit “G”) Brown and Roy Keezel, without clarification from the court, along with Doug Harper determined that this court’s order did not apply to the Administrative Commission.

This is important in that WorldPeace is asking for a Show Cause Hearing to shut down the Independence Heights Project which began to be built after the Administrative Commission came into being on February 8, 2003.

WorldPeace would show the court that it is an absolute lie that when an Administrative Commission comes in and takes over the functions of the session that the Administrative Commission is no longer responsible to any obligations of the session. If the session was designated to run Heights Presbyterian Church so is the Administrative Commission. If the Session is enjoined by this court, then so is the Administrative Commission. What is interesting here is that Brown has deliberately acted in contempt of the court's order and now after the Independence Heights Project has begun, after his bad acts, after WorldPeace was stopped from filing any other further motions, Brown comes in and tries to justify his bad, corrupt, and contemptuous acts.

WorldPeace would show the court that the statement that there has been no session meetings is in part true. However, Heights Presbyterian Church continues to go forward and money is continuing to be spent and people are continuing to be appointed to leadership positions but how this happening is a secret.

It is very interesting that Brown does not say that the Administrative Commission is not communicating with some members to the session. What Brown says is that there has been no session meeting. It is an absolute lie that the Administrative Commission has not allied themselves with the corrupt rouge members of the session and who are doing their bidding.

The amount of the corruption in this matter is great. The objective of the Administrative Commission is to cover up Joe Delgatto's bad and corrupt acts. The Presbyterian Church cannot allow the corruption to be exposed for public viewing that Delgatto and his co-conspirators stole $600,000 from Heights Presbyterian Church and obligated Heights Presbyterian Church to a $4.7 million corrupt HUD housing project which purchased property for $230,000 when it was only valued at $37,000.

WorldPeace would also show the court that all of these transactions were done in secret. Why was everything done in secret if it was all perfectly legal? The answer to that is as clear as a bell. The Independence Heights Project is corrupt and some of the Defendants are subject to being indicted.

WorldPeace would show the court that the entire point of this lawsuit was to stop and slow down and investigate and make the congregation aware of the Independence Heights Project. The entire purpose, focus, and actions of the Administrative Commission have been to further hide the actions of Delgatto and his co-conspirators. If it were not for the Independence Heights Project, there would not be a lawsuit except with regards to the audit. The entire point was to stop and investigate this project.

WorldPeace would show the court that the Administrative Commission has in fact proceeded on with the Independence Heights Project without communicating with the session, congregation, or any other honest persons. The question at this time is why? Why have all of these acts been done? HUD could have put this project on hold, but that is not what happened. The Independence Heights Project is not complete but it is proceeding.

Brown and the other attorneys in this matter, McGehee, Keezel, the Presbytery of New Covenant, and the Administrative Commission have all conspired to ram this project through. There has to be a question as to what is the hurry? Why was there a deadline on pushing this project through? The answer is that this project cannot stand the light of day, it cannot stand a true and open investigation, and the Presbytery was required to move as fast as it could in order to manipulate the situation in every way possible to hide the corruption.

WorldPeace would show the court that there can be no doubt that this kind of action is corrupt and there can be no doubt that at the center of this matter people are getting paid off.

WorldPeace would show the court that the prime mover and motivator in the Independence Heights Project was Tom Lord. Plaintiff alleges that Lord is at the core of the corruption. Without Delgatto and the corrupt members of the Presbytery, Lord could have never pulled off the Independence Heights Project.

WORLDPEACE MOVES THIS COURT FOR A SHOW CAUSE HEARING BEFORE THE END OF JUNE FOR THE PURPOSES OF STOPPING THE INDEPENDENCE HEIGHTS PROJECT

WorldPeace would show the court that nobody was out any money and that this project was not started until after Brown lied to this court about the purpose of the Administrative Commission on February 10, 2003.

WorldPeace would show the court that without any input from the congregation or the session, the Administrative Commission supported the corruption by not only approving but actually beginning to build the Independence Heights Project.. All of this was done in secrecy.

WorldPeace would show the court that there has yet to be a complete and open accounting to the congregation regarding the Independence Heights Project. There has yet to be a critical look at this project. The entire purpose of the Administrative Commission was to keep John WorldPeace from asking questions that everyone knew would collapse this project.

WorldPeace would show the court that contrary to the Book of Order, Mike Cole, General Presbyter of New Covenant, the Administrative Commission, and Delgatto have all refused to allow WorldPeace to become an official member of Heights Presbyterian Church. It is obvious why WorldPeace is not being allowed to become a member of Heights Presbyterian Church.

WorldPeace would show the court that everything about the Independence Heights Project is a farce and is corrupt. No one had anything at stake in this matter at the time that the Administrative Commission was appointed. Therefore, any monies that are lost or anybody that has obligations because of moving forward without resolving this lawsuit are at their own peril. Therefore, any kind of bond that needs to be set should be set for no more than $100.

WorldPeace would show the court that the Independence Heights Project is corrupt and that the Independence Heights Project does not even meet HUD's own guidelines because there is no amenities close to the Independence Heights Project. There are no grocery stores, theaters, barber shops, etc. The Independence Heights Project is an island within a desolate and dangerous community.

WorldPeace would also show the court that the entire Interim Report is in fact a lie and all of the lies that have been included in that report will come out during a Show Cause Hearing.

WorldPeace would also show the court that members of HUD and other independent persons will be subpoenaed to appear at the Show Cause Hearing and we will in fact get to the bottom of the Independence Heights Project matter. We will also get to the bottom of how the Administrative Commission has determined to obligate the finances of Heights Presbyterian Church to the Independence Heights Project. We are also going to find out the extent of involvement of each particular party.

WorldPeace would show the court that not a single affidavit accompanies Brown’s status report. Not a single member of this corrupt ring of rogues has signed their name swearing to one single fact in the status report.

The only person that is currently on the hook for Rule 13 Sanctions and Chapter 9 and 10 Sanctions and for potential disbarment is Reagan Brown.

WorldPeace would show the court that if these lies were in fact true, the entire Administrative Commission would have lined up to sign off on an affidavit stating such.

WHEREFORE PREMISES CONSIDERED, WorldPeace prays this court to set a Show Cause Hearing and ORDER the Defendants to appear and Show Cause as to why they were not in contempt in moving forward with the Independence Heights Project and to show why nothing has been done by the Administrative Commission in regards any issue other than the Independence Heights Project and for such other and further relief as this court deem proper.

Respectfully submitted,

John WorldPeace

I certify that a true and correct copy of the foregoing pleading was forwarded to opposing counsel on June 11, 2003.

John WorldPeace

WorldPeace would show the court that he has not been disbarred because the Judgment of Disbarment was not a Final Judgment nor was it an interlocutory order.

WorldPeace will shortly file a Notice of Filing with this court which will include WorldPeace’s Motion to Modify the Judgment of Disbarment and Motion for New Trial that will be heard on June 23, 2003, in the 269^th District Court.

In brief, the trial judge did not have personal or subject matter jurisdiction over WorldPeace because the Commission for Lawyer Discipline did not file five of the six complaints within the Commission v. WorldPeace lawsuit with the Supreme Court as required by Rule 3.01 of the Texas Rule of Disciplinary Procedure. Consequently, no order was issued by the Supreme Court of Texas per Rule 3.02 of the Texas Rules of Disciplinary Procedure appointing Judge Fry to hear five of the complaints. The Judgment of Disbarment is therefore void as to these five complaints.

Further, the trial court illegally severed WorldPeace’s mandatory counter claims which is an abuse of discretion and the Judgment of Disbarment will therefore be vacated by the trial court or the Appeals court.

Lastly, the sixth grievance was barred by res judicata because it had already been tried in the 281^st District Court six months prior to the Commission v. WorldPeace trial. In the WorldPeace v. Collins lawsuit in the 281^st District Court, Collins, the sixth complainant in the Commission v. WorldPeace lawsuit, did not file a mandatory counter claim which was the basis of the Commission’s lawsuit against WorldPeace. Therefore, the sixth complaint in the Judgment of Disbarment will be vacated.

Further, the trial court illegally disbarred WorldPeace for exercising his Fifth Amendment rights in the grievance process and allowed the Commission to present evidence on multiple rule violations without the required expert witness while at the same time refusing to allow WorldPeace to testify as an expert witness.

The chances of the Judgment of Disbarment against WorldPeace holding up on Appeal is slim and none. There is just too much case law on these issues for the Judgment to stand.

Lastly, WorldPeace would show the court that in 1993 Dawn Miller, attorney for the State Bar, filed suit against WorldPeace years after the statute of limitations ran. The suit was dismissed with prejudice and marred WorldPeace’s good name.

Three years ago, when the same Dawn Miller, who is now the Chief Disciplinary Counsel for the State Bar of Texas, began to try to build another frivolous and groundless case against WorldPeace, WorldPeace told Dawn Miller that he would shut down the grievance process if she continued in her bad acts. Miller continued and WorldPeace challenged the law regarding grievances and refused to negotiate any settlement with the State Bar.

In a nutshell, WorldPeace determined three years ago to shut down the State Bar grievance process and to have Dawn Miller terminated and disbarred.

The problem with the grievance process is that any disgruntled client can make the most frivolous complaint and subject the attorney to being disbarred even if the attorney won the underlying case for the client which WorldPeace did in two of the six complaints.

The global problem is that a client has an almost insurmountable task of getting by the “suit within a suit” requirement in an attorney malpractice lawsuit but none of that significant law applies to the grievance process.

Where a client does not have a shred of hope of a successful suit against an attorney in a malpractice suit, in the grievance process the alleged failure to return a phone call on a non-existent cause of action can result in disbarment.

If attorneys are going to be held to two distinctly different standards of care, then to protect their law licenses the average practicing attorney is going to have to significantly increase his or her fees and exacerbate the already lack of access the general population has to the legal system due to the expense of trying a lawsuit.

WorldPeace would show the court that the March 24, 2003 Interim Report is full of lies and statements which corrupt, skew, and spin the truth in such a way that it attempts to cover up the lies and corruption of Joe Delgatto and the other Defendants.

FACTUAL BACKGROUND RELATING TO THE HEIGHTS PRESBYTERIAN CHURCH INVOLVEMENT IN THE

INDEPENDENCE HEIGHTS PROJECT

 

HEIGHTS PRESBYTERIAN CHURCH'S PRIOR PARTICIPATION IN THE HUD

LOW INCOME HOUSING PROJECT

 

WorldPeace would show the court that the Houston Housing Management Corporation is a for-profit corporation that manages the Heights Towers and Heights House Project which Heights Presbyterian Church has been involved in along with three other churches for the last thirty years. Houston Housing Management Corporation is owned by Tom Lord and Lord therefore has a financial incentive in developing the Independence Heights Project which he assumes he will manage.

WorldPeace would show the court that Lord, through the manipulation of the Independence Heights Project, has scammed off money through corrupt means to build this project and WorldPeace would show that Delgatto, Charlie Windham, Walter and Patty Ellis, and a few others have pushed this project through for the purposes of enhancing their own financial net worth.

WorldPeace would show the court that the number one reason that these acts are alleged is because the Independence Heights Project was kept ultra-secret and away from the congregation and the majority of the session. The secrecy of the Independence Heights Project continued even after suit was filed after the project become generally known.

WorldPeace would show that when the Presbytery of New Covenant and the Administrative Commission got involved, they did nothing but continue the covert activities and cover up.

WorldPeace would show the court that there is no reason that a legitimate project for a legitimate purpose would be covered up to the extent that this project has been covered up for two years except that there were some payoffs and kickbacks to the principal promoters of the Independence Heights Project, ie Tom Lord, Delgatto, Windham.

WorldPeace would show the court that there is no doubt that Lord was going to make money as the manager of the project. However, in a legitimate project Lord would have had to bid upon the management services. There is nothing in the Interim Report about the fact that Lord would have to bid on the management of the Independence Heights Project. It is secrecy that has surrounded this project from the beginning and secrecy implies corruption.

It is a fact that the congregation of Heights Presbyterian Church have been kept in the dark for the entire period of time; even after suit was filed and even after the court signed an injunction and even after the Administrative Commission was formed there has been secrecy.

WorldPeace would show the court that there is no way that a legitimate project would require this level of secrecy. There is no way that a legitimate project would require that the entire congregation be kept in the dark regarding this project.

THE INITIAL INVOLVEMENT OF HEIGHTS PRESBYTERIAN CHURCH IN

THE INDEPENDENCE HEIGHTS PROJECT

WorldPeace would show the court that the project was begun by the Houston Housing Management Corporation, which is owned by Tom Lord. The prime mover here was Tom Lord. It was not the four churches who own Heights Tower and Heights House. It was Lord.

This was done because of Lord’s desire to make money not only managing the project but also scamming off monies from the HUD monies coming into the project by appointing his CPA, his architects, his brokers, etc. to manage the process as well as to take kickbacks under the table from those various people as he moved this project through. Lord makes money by managing the project.

WorldPeace would show the court that the number one red flag in this project is that the $37,000 piece of property listed on the tax rolls was purchased for $230,000 after Lord's appraiser put a bogus value on the property.

WorldPeace would show the court that there is no question but that the tax rolls are not always up to date as to what a particular piece of property is worth. However, a piece of property in the center of the ghetto, not close to anything and in one of the highest crime areas in the city of Houston, cannot be worth $230,000 when it is on the tax rolls for $37,000. This was undeveloped land.

WorldPeace would show the court that there has been a lot said about Mayor Brown’s “Super Neighborhoods”. The reality is that in WorldPeace’s efforts in helping Kurtyce Cole run for Councilmen of District B in 2001, which is one of the two Black districts in Houston, WorldPeace found out that the “Super Neighborhoods” are nothing other than a campaign promise without any substance.

WorldPeace would show the court that none of the funds to develop these neighborhoods have been allocated in the capital budget of the city of Houston. Even if they were, those funds would not be available for another four or five years.

Further, WorldPeace would show the court that “Super Neighborhoods” was simply Mayor Brown's effort to bring out the Black vote. The “Super Neighborhoods” are simply a farce and a lie to manipulate the Black vote.

WorldPeace would show the court that the Interim Report talks about the Heights boards; being the board of the Heights Towers and the Heights House. Those boards and members are all members of the four churches that own and sponsor those projects. Therefore, there is an inter-relationship between the boards that run those two projects and the churches that sponsor those projects.

WorldPeace would show the court that Reagan Brown, all the way through his report, tries to act like there is this separation between Heights Presbyterian Church and the Independent Heights, Inc. non-profit Corporation. The reality is that the members of Heights Presbyterian Church and Heights Christian Church are the only ones who are allowed to be on the Independent Heights, Inc. board.

There is still a question that has not been answered as to who owns the stock of Independent Heights, Inc. All indications are that the stock is equally owned by Heights Presbyterian Church and Heights Christian Church. Therefore, for Brown to say that there is no connection between the two entities is an outright and blatant lie.

WorldPeace would show the court that Brown alleges that the four sponsoring churches of Heights House and Heights Towers contemplated a non-profit corporation for the Independence Heights Project. Again those boards of the Heights House and Heights Towers are made up of members of the four sponsoring churches. All of the stock of those corporations are owned by the churches. Therefore, there is not an arms length transaction between the non-profit corporation and any one or all of the particular churches.

WorldPeace would show the court that the reality is that under Section 202 the project requires that a non-profit organization sponsor the project. Without Heights Presbyterian Church or Heights Christian Church, the Independence Heights Project could never get off of the ground. It required a church or an entity like a church to sponsor the project.

Tom Lord could not set up a non-profit corporation and make this Section 202 project happen without the churches participation. It was essential that Lord bring in, as a co-conspirator, Delgatto and Rosemary Hammond from Heights Christian Church in order to get this project off of the ground.

WorldPeace would also show the court that Saint Andrews Episcopal Church and All Saints Catholic Church were in the other two projects and yet refused to get involved with the Independence Heights Project. This runs up an additional flag as to why these particular churches who had along with Heights Christian Church and Heights Presbyterian Church been running two other projects for thirty years did not want to participate in the Independence Heights Project. What is it about the Independence Heights Project that these other two churches refused to participate in? The reason that they did not join in is because it is a corrupt project and they refused to be bought off by Tom Lord.

WorldPeace would also show the court that Tom Lord has made several statements that the Independence Heights Project resistance is due to WorldPeace and his mother, Joyce Wolter's, about racism. If that applies to WorldPeace, which is of course denied, then maybe Saint Andrews Episcopal Church and All Saints Catholic Church are also racist and that would be the reason why they refused to participate in the Independence Heights Project.

WorldPeace would show the court that it is not just WorldPeace and his mother who oppose this project. There were two other churches that had been long time associates of Heights Christian Church and Heights Presbyterian Church who also saw the corruption in the Independence Heights Project. The difference was that the corrupt people like Rosemary Hammond and Joe Delgatto were not involved in the decision process at those other two churches.

The other two churches had a legitimate process by which to evaluate these projects and they determined that the Independence Heights Project was not a valid project. No one is going to say that the Catholic Church is racist. The Catholic Church is present all over the world. The Catholic Church if anything is building church communities everywhere. Yet they determined that they did not want any part of the corrupt Independence Heights Project or Tom Lord.

WorldPeace would show the court that the two sponsors entered into an extension of the earnest money contract on July 5, 2002. However, there was no notice to the congregation of Heights Presbyterian Church that any of this was going on. The papers that were signed in the Independence Heights Project were originally signed in 2001 and nobody at Heights Presbyterian Church knew about this project until February 2002, nine months later.

WorldPeace would show the court that Brown says that Heights Presbyterian Church did not pay any part of the initial $2,500 for this sponsorship but he does not say who actually did pay that money. The money was probably paid by Tom Lord, which I believe is illegal because Tom Lord is a for-profit corporation owner who intends to manage the Independence Heights Project. Lord put money into the project in order to try to run his scam on HUD.

WorldPeace would reiterate to the court that Diane Springer, a member of Heights Presbyterian Church, paid $5,000 into the Independence Heights Project and the letter from Hammond to Springer definitely stated that the $5,000 committed Heights Presbyterian Church to the Independence Heights Project. (Exhibit “E”) WorldPeace alleges Lord gave the $5,000 to Diane Springer.

WorldPeace would show the court that Brown has made a big deal about the fact that it was not Heights Presbyterian Church who actually paid the $5,000.

WorldPeace would further show the court that it does not matter who paid the $5,000. What matters is that the $5,000 obligated Heights Presbyterian Church to the Independence Heights Project. All of the documents signed between May 2001, to January 2003, were signed by Delgatto without the knowledge or approval of the congregation, session or the Presbytery of New Covenant.

WorldPeace would show the court that Delgatto testified to this in open court. Delgatto had no authority from any of these entities to obligate Heights Presbyterian Church to this project. Delgatto had no authority from anyone to obligate Heights Presbyterian Church to this project.

WorldPeace would show the court that Brown seems to indicate that as a member of the Board of Heights House and Heights Towers that Delgatto somehow had authority to sign off on the Independence Heights Project. However, no documents that show that authority have been produced by Brown.

Not only that, the boards of Heights House and Heights Tower are not able to obligate and sponsor a Section 202 project. The sponsorship of the Independence Heights Project has to be from a non-profit corporation, which would be a church and not from the boards of the other two projects. Brown conveniently forgets to mention this part.

WorldPeace would show the court that Saint Andrews Episcopal Church did not sign onto the project because of the concerns over the language in the firm commitment from HUD. That language said that the churches would be committed for any shortages on the building of the project. Saint Andrews Episcopal Church understood that the Independence Heights Project was different from the other two projects.

WorldPeace would show the court that again Lord says that the housing corporation, (which we are not sure exactly which housing corporation Brown is referring to because there is a very tricky sameness in the names of the Houston Housing Management Corporation and the Houston Housing Corporation of Greater Houston. Both names include the housing corporation. Therefore, Brown is not clear as to which one he is particularly referring to nor who owns which particular corporation.)

WorldPeace would show the court that the non-profit Houston Housing Corporation of Greater Houston is simply a front for the Houston Housing Management Corporation. Both are owned and controlled by Tom Lord.

WorldPeace would show the court that the laws of Texas allow these corporate entities to be independent of each other but the reality is when Tom Lord owns the subsidiary corporation and the subsidiary corporation is part of the larger non-profit corporation then we all know that it is Lord who is the connecting thread through all of these corporate entities. It is Tom Lord’s housing corporation that hired the appraiser O'Connor and Associates to determine that the property was worth $230,000.

WorldPeace would show the court that no one can safely assume that that property value was not inflated and that Lord did not get a kickback of a certain amount of cash money from the sale of the property in order to make this project happen. It would be very important and useful to look at exactly where the $230,000 that was paid to the property owners went. This is something that will be investigated by the Inspector General who is charged by the United States to investigate crimes within the Department of Housing and Urban Development.

WorldPeace would show the court that the appraisal was also bogus because there was only one. Normally if you are going to build a project like this,you need an independent appraiser and not someone connected to Tom Lord. If you do have independent parties trying to determine the value of property, then you get separate appraisals for that property which was not done here. The purpose of the O'Connor appraisal was simply to inflate the price of the property in order to create enough kickbacks to pay people like Delgatto, Walter and Patty Ellis, and Windham .

WorldPeace would show the court that this project was never about helping the poor or about racism. However, it was in fact about profit, greed, and money in Lord's pocket.

III. SESSION APPROVAL OF THE HEIGHTS PRESBYTERIAN CHURCH PARTICIPATION IN THE INDEPENDENCE HEIGHTS PROJECT

WorldPeace would show the court that Joyce Wolter was not just a session member, but she was also a trustee of Heights Presbyterian Church and responsible for these kinds of investments.

There was a meeting between WorldPeace, Lord and Delgatto and others on April 19, 2002, which was on a Friday. Lord says that WorldPeace did not want to read the documents at that meeting. WorldPeace says all the Independence Heights Project documents were not there. The reason that WorldPeace did not look at those documents at that time was in fact because they weren’t there and WorldPeace was going to look at those documents the following week.

However, WorldPeace did not know that there had been a special meeting of the session called, which was illegal, for Sunday two days later. The meeting was illegal per Roberts Rules of Order which the Book of Order incorporates. Delgatto did not state what the nature of that special session meeting was.

When the session met, Delgatto ran through a vote to approve the sponsorship of the Independence Heights Project. This was done undercover. This was done by Delgatto and others knowing that they had trouble with WorldPeace and they wanted to try to legitimatize the project as quickly as possible.

However, none of this was done until after the meeting with WorldPeace. The meeting with WorldPeace was set up a week prior and so Delgatto made an announcement as he was required to do on the 14^th of April that there would be a special session meeting on the 21st. But there was no statement as to what that special session meeting was for and the reason that there wasn’t was because if it had been known that there was a special session meeting coming up on Sunday, the 21^st, WorldPeace would have demanded to see the documents on the proceeding Friday and not waited until the next week.

WorldPeace was told by Lord and others that there was no particular deadline on the project before May 31^st and therefore there was no rush for WorldPeace to look at this 7 or 8 inch stack of documents that Tom Lord was trying to get WorldPeace to view in a few minutes.

The Book of Order was not followed in that special session meeting and therefore the session meeting was invalid. Nobody really understood what was going on. It was put out by Delgatto like it was simply a routine meeting and what it was in fact was his desperate need to get some kind of legitimization for his corrupt project.

Mr. Lord’s letter of April 26^th states only that the contribution was $10,000.00 to be returned if there was no operating deficit. What that means is if there is a operating deficit not only is Heights Presbyterian Church not going to get its $10,000.00 back, but it is going to have to make up that operating deficit.

This is something that has been denied from the beginning. HUD will not simply take back the project. There are obligations that go along with sponsoring this project.

WorldPeace alleges that any California church that pays it $20.00 of filing fees is not going to get approved for a Section 202 project. The church has to have some assets and some credibility or it is not going to get approved. All along it has been indicated that this is no big deal. Yet everything was covered up. Lord says it is illegal, for anybody to receive any kick backs. That is why it is done under the table.

I don’t know what foolish people that he thinks he is talking to here. We certainly don’t expect to see any legitimate checks written. What we intend to do is check with the bank accounts of the people that have put their hands on this money and find out if they can account for all the money they received.

Lord absolutely lied when he said the church cannot be bankrupted by this project. This is the reason that St. Andrews and all Sanits got out of the project. They did not want to be bankrupted. That is why they refused to sign off on the firm commitment from HUD. They knew they could be bankrupt. Lord is nothing but a liar. Where Lord verified these statements to 280th District Court by affidavit, Lord perjured himself. That is all there is to it.

Lord has a financial interest in the management of Independence Heights Project and consequently his testimony is definitely skewed regarding the events involving Independence Heights Project between May, 2001, and the creation of the Administrative Commission in February 2003.

On October 18, 2002, Diane Springer did write a $5,000.00 check to Independence Heights, Inc, which obligated the church. (Exhibit “E”) Delgatto, Ellis, Windham and others knew that if Springer put the money into the church, the session would have to vote to put the money into the project. They knew that was not going to happen and therefore they did this behind everybody’s back and had Springer pay her money directly into Independence Heights, Inc. Corporation instead of paying it through the legitimate avenue which would have thrown up red flags everywhere.

Delgatto and his co-conspirators were determined not to allow this project to get out into the general congregation because he knew it would be killed.

Brown continues to state that there was no funds paid by the Heights Presbyterian Church. This is not the point. The point is that the money came from Diane Springer because she was a member of the church. The money was funneled around the church and the point is that the money obligated Heights Presbyterian Church to the project.

The problem is the obligation not who actually wrote the check. Nobody has alleged Diane Springer would have written a check to this project had Heights Presbyterian Church not been involved. The question is whether Lord gave Springer the money to obligate Heights Presbyterian Church to the Independence Heights Project.

The question again is who owns the stock in the Independence Heights, Inc. Who knows?

Delgatto conveniently has not made any statements about that. The question is who owns the stock. Who owns the stock in the non-profit corporation of Greater Houston? The answer is Tom Lord. But that is something that has been kept under cover as well.

Independence Heights, Inc. hired Tom Lord’s architect, Jim Gwin. There was no competing bids. There was no concept plans drawn up. They just handed over the project to Jim Gwen per the direction of Tom Lord. Again more kick backs. Tom Lord’s running the show.

Money received was under the table.

Mr. Brown has not provided any of the HUD firm commitments and further there is no supporting affidavits to this Interim Report. There are no supporting affidavits to his status report.

The reason is that all these people involved in the Independence Heights Project are corrupt and none of them are stupid enough to put their name on an affidavit. The only person who is really liable is Joe Delgatto for his comments in court under oath and Reagan Brown under Rule 13 TRCP and Chapter 9 and 10 Sanctions under the Texas Civil Practice and Remedies Code as well as the Texas Discipline and Rules of Professional Conduct for his lying to the court and filing these bogus documents.

C. REQUEST TO THE HOUSING CORPORATION AND HUD FOR DOCUMENTS FROM THE ADMINISTRATIVE COMMISSION

The Administrative Commission is trying to manipulate the problem that Delgatto has created. They are trying to make statements about corporations as opposed to church ownership and all kinds of other things which is nothing more than a manipulation to cover the bad acts of Joe Delgatto and the other Defendants.

By the time the Administrative Commission got involved in February 2003, everything had already been done. Delgatto signed his last documents on January 15, 2003, and that was because the last earnest money contract was going to expire on January 31, 2003. The Administrative Commission did not come into the picture until February 8, 2003.

Mr. Brown says that there is only $5,000 contributed by Heights and $5,000 by Heights Christian Church. The reality is that there is more than $10,000 that has been paid out in this process and the question is where did that money come from. The answer is that the money came from Tom Lord illegally under the HUD funding rules because Lord as a for profit corporation and is not allowed to be funding this project.

Delgatto knew that the congregation of Heights Presbyterian Church was not going to fund this project. So all of this had to be done under the table in order for him to receive his bribe. Independence Heights, Inc. is owned 50% by Heights Presbyterian Church.

Again, money was paid under the table and again where are the documents that support this Interim Report.

Mr. Brown makes a statement that the Administrative Commission doesn’t have any ownership in the Independence Heights, Inc. but again this is just a play on words. The Administrative Commission is a part of the Presbytery of New Covenant and the Presbytery of New Covenant is a part of the Presbyterian Church USA. Mr. Brown has alleged that Presbyterian Church USA owns all assets of all the Presbyterian churches.

The Administrative Commission doesn’t own anything but they are agents for the Presbyterian Church USA who does own everything; either directly or through the individual churches like Heights Presbyterian Church. The question is why proceed with the project when the congregation is against it? Why not just have a vote by the congregation?

The Administrative Commission had Brown check the documents provided by Tom Lord, owner of the Housing Corporation. Why did Brown think he was going to get the truth. Tom Lord is the corrupt individual who has pushed this project in from the beginning. Why would he give the documents to Mr. Brown or anyone else that would literally hang him? How ridiculous.

Where is the report from Mr. Brown? Why hasn‘t the congregation been able to see it? The reason is that it is a lie.

3. THE ISSUE EFFECTING HEIGHTS ABILITY TO PARTICIPATE AS A SPONSER WITH INDEPENDENCE PROJECT CONTROLING PROVISIONS

Regarding this particular provisions of the Book of Order, these projects are supposed to be conceived by the session, submitted to the Presbytery, then sent back to the session if approved by the Presbytery and then put up for a vote from the congregation. This is the process and the process was not followed with regards to Independence Heights Project.

Delgatto admitted in open court to signing all these documents without the permission or authority of the session, congregation or the Presbytery of New Covenant. Now Brown tries to say that the earnest money contract is not in fact the purchase of a property.

Well, legally speaking and technically that is absolutely true. But what he does not say is that if Delgatto did not intend to obligate the Heights Presbyterian Church to that property then he was committing a fraud when he was signing those documents to purchase that property.

Who is obligated to purchase that property? Was it actually a purchase per the Book of Order? The answer is No.

But the reality is that Delgatto intended to purchase that property and he intended to purchase it without permission of the Presbytery, session or the congregation. That is the point that Brown skims over.

Brown makes a big deal of his allegation that he has talked to two stated clerks from all of the Presbyteries all over the United States. The question is why didn’t he talk to members of the other Presbyteries or the members of the Synods or the members of the General Assembly or even the members of Heights Presbyterian congregation?

The reason is that he was very careful to only talk of those people who would give him the answers that he needed to hear in order to further the corruption.

On June 7, 2002, WorldPeace set up a web page called Presbyterians-R-US.com in order to communicate with the members of the Presbyterian Church USA.

It would seem that Brown was doing his job he could have accumulated 1700 emails to all the Presbyteries, all of the Synods and the General Assembly throughout the church and ask their opinion as to whether anybody had any knowledge of these particular kinds of transactions. This is what WorldPeace did. He chose not to do that. What he chose to do instead was to simply choose the people who would give him the answers he wanted to hear.

Brown wants to use the applicable Texas Law to make this legal distinction between an earnest money contract and the purchase of property. Again he ignores completely the fraud involved in regards to intent, as to whether Delgatto intended to obligate Heights Church or not. If as Brown stated, that if the earnest money contract was not an obligation then what we have is Delgatto defrauding the individual selling the property by saying that the church was prepared to buy the property and in fact it was not.

Even though there wasn’t a purchase of property under the strict rules of the Book of Order because Heights Presbyterian Church’s interest had been transferred into the Independence Heights Inc., separate entity, yet it was still controlled by the members of Heights Presbyterian Church. The reality is that there was an intended purchase and that what’s important and not what corporation actually bought what at what particular time. The Book of Order were violated.

The project should have gone to the session, to the Presbyterian and back to the session, to the congregation and then signed off by all the trustees at the church. Of course the Defendant’s knew that Charlie Windham was the only corrupt Trustee. They got Windham to sign off on the project without authority from the session. And without the other two trustees one of which is the Plaintiff and the other, who is now deceased

WorldPeace would also show the court that the notes of the session meeting of April 21 did not indicate any statements by Delgatto that he had done this project in secret with James McClain, Charlie Windham and Walter Ellis a year prior to this matter coming up in the session illegally on April 21^st.

B. POTENTIAL LEGAL AND FINANIAL LIABILITY FOR HEIGHTS PRESBYTERIAN CHURCH

The question is who owns the Independence Heights Inc? The earnest monies that were paid on the contract were greater than $10,000. The question is who made up the differences. The allegation is Tom Lord did which is a violation of the HUD regulations because Tom Lord is not a not for profit corporation. Tom Lord was financing and funding the project. IHe funneled the money into Independence Heights Inc.

This is illegal. This is a lie. This is something that the Inspector General will be looking into.

The reason that St. Andrews Episcopal Church got out of the project on October 31, 2001 was because it was based on HUD’s firm commitment application, which says that the sponsor will be liable for the cost of any front end cash requirement should the cost of the project exceed the fund reservation amount, which was only $10,000. This is a 4.7 million dollar project that started out as a 3.5 million dollar project and it was very likely that the project would over run as much as a million dollars. If that happened Heights Presbyterian Church would be bankrupt. That is why St. Andrews refused to get in it. And that is why Delgatto signed off without telling anybody in the church what he was doing.

Heights Presbyterian Church was obligated by Delgatto at the time he signed the firm commitment that said that Heights Presbyterian Church would make up any of the deficits. Between May 5, 2001 and January 22, 2003 there was an obligation by Heights Presbyterian Church to pay any deficits. The problem here is that when the Administrative Commission got involved they did not shut down the whole project as corrupt. What they did was go in and save the project and move it forward? This was not their mandate. Their mandate was to get to the bottom of the problem.

The question is what was the hurry. Why couldn’t the Administration Commission put the brakes on the project? Why didn’t they? The answer is that the corruption runs into the Presbytery as wells as Delgatto and other Heights Presbyterian Church members.

The Administrative Commission got a statement from HUD that said no funds are required to meet the expenses of the project of the occupancies until final closing. What that says is that after final closing and for the next forty years as the HUD employee told WorldPeace, all the monthly deficits will be funded by the sponsor; being the Independence Inc. whose owners are Heights Presbyterian Church and Heights Christian Church.

More manipulations by Mr. Brown of the truth. In his last statements he says that the church is not going to be committed to any funding deficit on the building of the project but he never says that Heights Presbyterian Church after final closing will not be obligated for the monthly deficits and the operating expense. Mr. Brown is a liar and he is lying to the court and for this he should be disbarred.

There are no merits. St. Andrews Episcopal Church and All Saints Catholic Church both

determined that this was a bogus and corrupt project. There are no merits to this project. It was conceived in secrecy and conceived and obligated to in the back rooms of Tom Lord’s offices.

Lord found that Delgatto was just the corrupt preacher that he needed. They also knew that Heights Presbyterian Church had a half a million dollars in assets which would help the sponsorship application, which I believe was altered before it was sent to HUD.

This is another reason that an audit is not wanted by the Administrative Commission

because it would show that lies were told on the application that were sent to HUD and people will go to jail.

At the time that this matter was coming to a head, the lawsuit had already been filed. The congregation wanted a hearing, the court was going to offer an open hearing and signed an injunction stopping any secret meetings about the project without WorldPeace presence.

WorldPeace got rid of Diane Fieler McGee, the attorney for Heights Presbyterian Church, who was never really legally hired and yet all of this was undone by the corruption of the Administrative Commission and Brown.

On February 8, 2003, just two weeks after Delgatto extracted himself to some degree from the Independence Project, eight of the twelve members of the session went to the Presbytery unannounced and demanded an Administrative Commission to be set up. The other four members of the session were not informed.

There is a statement by Brown that there was no complaints as to setting up the Administrative Commission. There was no complaints because Delgatto and his co-conspirators went to the quarterly Presbytery meeting without informing the opposing session members. Just another example of Delgatto’s lies. If you want to know when Delgatto is lying just look and see if his lips are moving.

The Rules of the Book of Order require that the Presbytery, after a thorough investigation and after a full opportunity for each member of the session to be heard, then they appoint an Administrative Commission. They did not even hear the whole session. They did not even call the four members who was not there. Therefore, they violated the Book of Orders but this is nothing new.

What is very interesting is that thirty-five complaints were filed against Delgatto by members of the church back in March. On May 8, 2003 there was a quarterly Presbyterian meeting and no investigatory commission or committee was set up to investigate those complaints against Delgatto. The reason why is that Presbytery of New Covenant and its officers are just as corrupt as Delgatto.

THE CONDITIONS FOR RESOLVING HEIGHTS PRESBYTERIAN CHURCH INVOLVEMENT AND INDEPENDENCE HEIGHTS PROJECT

Per HUDs firm commitment, Heights Presbyterian Church is obligated for those monthly operating deficits. They are obligated indirectly through Independence Heights, Inc. It is a lie to say that they are not.

The question is real simple. Why didn’t the Administrative Commission just get out of the project? No money had been paid. Nobody was out any money. Nobody was obligated to anything. The church was not committed to anything. The church congregation had serious reservations. Two other churches had dropped out of the project. Why did the Administrative Commission ram the project through. The answer is because there is money being paid under the table.

Money had in fact already been paid and it is entirely possible that the health and well being of the Defendant’s have been in jeopardy had this project not gone through; particularly Delgatto. It makes a lot of sense that if Delgatto took money under the table to put the project through and then the project came to an end then those who paid him would harm him.

Without Heights Presbyterian Church as a sponsor, there is no Independence Heights Inc. There is no HUD project. Heights Presbyterian Church had to put up their assets. They had to fill out an application. I am sure that application was falsified. There are prison terms associated with falsifying those HUD applications and consequently this project has to be covered up, otherwise people were going to be looking at a federal prison sentences.

Joe Delgatto is one. Charlie Windham is another and potentially other people depending on who signed the application and supporting documents. It is also interesting that Rosemarie Hammond after this project was essentially closed refused to sign the last document that Delgatto signed and then she retired from being a minister. Coincidence?

In regards to the investigative commissions that were appointed to look into the accusation by Joyce Wolter against Joe Delgatto’s wife and her accusations against Delgatto, only one of those committees has been set up and it was the one regarding the accusation against Joe Delgatto’s wife.

The other commission about Delgatto has not been set up and in addition the Stated Clerk has refused to set up a commission to look at the thirty-seven accusations against Delgatto, since they were filed on March 8, 2003.

There was never any intention by the congregation to participate in the Independence Heights Project. Only the people that were receiving money under the table, being Charlie Windham, Joe Delgatto, possibly James McClain, Walter and Patty Ellis were behind this project. Nobody else. These people manipulated the session and others.

WorldPeace would also show the court that it is Presbytery who backed up Delgatto and it is the individuals at Presbytery, in particular Lynn Johnson, Art Greer and Mike Cole, who were involved in this project and who will be in trouble.

WorldPeace would show the court that Mr. Kaufman, who was the General Prebyster at Presbytery of New Covenant coincidently resigned right about the time this project was coming to a head in January 2003. Delgatto is still around due to this lawsuit

The reality is that WorldPeace ‘s lawsuit back in April, 2002 scared everybody. Joe Delgatto, Rose Maria Hampton and others at the Presbytery of New Covenant. They just coincidently faded away after January 2003.

There is no evidence that legitimate money was paid. Of course not. This is money under the table.

Lastly, the closing verse in Brown’s lying Interim Report exhorts the members of the congregation to be subject to the rulers and authorities and to be obedient. You do not obey evil doers. To be obedient to evil is to be obedient to Satan. When you find corruption and lies and evil you are not to obey to it. You are to challenge it and cast it out.

Reagan Brown is a liar. He has lied to the court. He has skewed the facts. There are people headed for jail for their manipulation and lies regarding Independence Heights Project.

The Inspector General will take of these matters. In the meantime the civil courts are the ones that must deal with the theft, the conversation and the fraud of Joe Delgatto and the other Defendants.

How can we manifest peace on earth if we do not include everyone (all races, all nations, all religions, both sexes) in our vision of Peace?

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