I, Roy Keezel, a member of the Administrative Commission

> illegally and outside the Book of Order

elected by New Covenant Presbytery to act in place of the Session at Heights Presbyterian Church, accuse Ms. Joyce Wolter, of committing the multiple offenses of persistently bearing false witness against her pastor and other elders at Heights Presbyterian.

> There is not a factual statement of what false statements were made by JW (Joyce Wolter) or which elders are being referred to.

I further accuse Ms. Wolter of the offense of repeatedly violating G.14.0207

> (e) Will you be governed by your church’s polity, and will you abide by its disicpline? Will you be a friend among your colleagues in ministry, working with them, subject to the ordering of God’s Word and Spirit.

> No facts are alleged which show a violation of this Rule.

> (f) Will you in your own life seek to follow the Lord Jesus Christ, love your neighbors, and work for the reconciliation of the world?

> No facts are alleged which show a violation of this Rule.

> (g) Do you promise to further the peace, unity, and purity of the church?

> No facts are alleged which show a violation of this Rule.

> (h) Will you seek to serve the people with energy, intelligence, imagination, and love?

> No facts are alleged which show a violation of this Rule.

of her elder ordination vows.

These offenses are contrary to Holy Scripture

> Which scriptures are being referred to here?

and the Constitution of the Presbyterian Church (U.S.A.)

> which parts of the Constitution of the PCUSA are being referred to here?

and I submit the following information in support of said accusations:

Ms. Joyce Wolter is a member and elder of Heights Presbyterian Church. As a member of the administrative committee I have received information that requires me to file this statement of offense.

> But there is nothing referring to what information has been received?

I request that a disciplinary case be opened against Ms. Wolter and that she be tried by the appropriate church body.

> Based on what? Mr. Keezel is an enemy of JW’s son John WorldPeace due to WorldPeace’s thrashing of Mr. Keezel in the courtroom. Mr. Keezel has a personal bias against WorldPeace which carries over to JW and Mr. Keezel should not be on the Administrative Committee.

Since the creation of the Administrative Commission for Heights Presbyterian Church, I have been privy to numerous interviews with members of the church and others.

> Which interviews with which members?

I have reviewed minutes of session meetings.

> Which minutes of which session meetings?

I have reviewed letters and statements by Ms. Wolter and others.

> Which statements and letters?

I have observed Ms. Wolter.

> When and where was JW observed?

On April 15, 2003, I participated in a meeting with her in which most of the offenses were specifically explained to her.

> Where was this meeting held and who was present and was it recorded and was there permission on the recorder to allow the meeting to be recorded? And since this is part of the accusation JW demands a copy of the tape.

She admitted that the accusation she had made were without facts but refused to recant them.

> And which accusation is Keezel talking about?

I was not always present when Ms. Wolter made unfounded and baseless claims against other members of the church.

> And if Mr. Keezel were a competent lawyer, he would know that he cannot testify to what he did not hear or observe because it is hearsay and unreliable.

She reiterated a summary of these claims in a signed statement dated March 12, 2003.

> And where is that statement and which specific claims is Keezel referring to as being violations of his above referenced rules.

She has falsely made claims of dishonesty, theft and scandalous conduct about members of Heights Presbyterian Church.

> What were the claims and which claims apply to which members?

She has questioned the integrity of several members.

> Which members?

Rather than bring an accusation before the church or the presbytery, Ms. Wolter chose to file suit against the pastor and elders and other parties alleging much the same in a lawsuit entitled, Joyce E. Wolter v. Joe Delgatto, et. al. in Cause # 2002-20203 in the 280th Judicial District Court of Harris County, Texas.

> Where is the rule that requires a trustee of the church to file an accusation prior to filing a lawsuit to preserve the assets which she is charged to protect? There is no such rule and certainly not in the rules alleged to have been broken by JW.

Ms. Wolter caused the church to be enjoined from conducting various aspects of the business of the church.

> The assumption is that a court of law issued the injunction and therefore there was substance to it which could not be overcome by the defendants.

The result is that the church has been virtually paralyzed.

> There are no facts which show how the church was paralyzed. It is ridiculous that one person could stop the preacher and sixty active members of the church plus the session and the Presbytery.

Ms. Wolter has made false and misleading statements about the participation of Heights Presbyterian Church in a HUD sponsored Independence Heights Project.

> Which statements were false. Further, none of the documents regarding the HUD project have been disclosed by the Administrative Commission to the congregation or to the court. So what statements are being referred to and where are the HUD documents that prove any of these undisclosed statements are false?

She alleged and continues to allege that the pastor involved the church in the project without authority and to the financial detriment of the church.

> Minister Delgatto, testified in open court and under oath that he obligated HPC to the Independent Heights project without authority from the session of HPC, the congregation of HPC or the Presbytery of New Covenant. This is not an allegation but a fact.

>As to the financial detriment of the church, no HUD documents have been produced and no financial records of the Independence Heights, Inc have been produced. Without the production of these documents no determination can be made as to whether there is a financial detriment or not. Again no facts to support the allegations of Keezel.

She alleged and continues to allege that the pastor and other members breached their fiduciary duties, lied and took bribes and kickbacks and stole the church's money and jeopardized the financial well being of the church.

> Where is the evidence that JW made these allegations. the financial statements produced by the Administrative Commission do not balance and show an unaccounted sum of money around $100,000. No financial documents have been produced. No summaries have been produced for 1997, 1998, and 1999. Without a full audit of the actual HPC records, these allegations cannot be proved either way. But what is a fact is that the financial numbers produced by the Administrative Commission on September 2, 2003 and September 28, 2003 regarding the year 2002 do not even match each other. That is a fact and that is true.

According to the minutes of the session meetings of the church, knowledgeable persons explained the project and the church's involvement on several occasions and had HUD official and participants speak to the session.

> Where are the documents that record these explanations? Who explained the project? What did they say? And how does what they say show that JW violated any of the above rules? And of course it goes without saying that Keezel was not present. And no recording were made of those meetings and so how does Keezel know what was said or not said other than by minutes that have not been produced.

After a thorough investigation by the Administrative Commission, her accusations of dishonesty, conspiracy and breach of duty were found groundless.

> Where are the records the Administrative Commission referred to. The Administrative Commission cannot even produce two financial statements that match. In accounting that creates problems because everything balances in accounting. Further, Joe Delgatto has already admitted his dishonesty in open court and consequently his breach of duty. And which other accusations against which specific members or people is Keezel talking about? This is just more unnamed generalities that are impossible to even respond to from a third rate attorney.

The church's participation was found legal and above board.

>The HUD documents have never been produced to show whether or not the participation was legal or not. All we have is the word of the Administrative Commission and most of what the Commission has said is as unsubstantiated as this rambling and unsupported like the accusation by Keezel. There are no facts. The best evidence of the relationship between HPC and the HUD project are the HUD documents which for some reason the Administrative Commission refuses to produce to the court or to the congregation.

The investigation showed that the church has never been liable for the project.

> No. The report of the Administrative Commission unsupported by hard evidence alleges that there is no liability for the project. The Administrative Commission has never answered the question as to why HPC needs to be involved at all if there is not requirement for its participation. And the Administrative Commission has never stated why when it took over in February 2003, HPC was not obligated to the project but the Administrative Commission without a vote from the congregation went ahead and finalized HPC’s obligation to the HUD project. The Administrative Commission is corrupt and so are all of its members especially Keezel.

Despite the result of the report, she persists in bearing false witness.

> And what are the false statements? Is anything said contrary to the lies of the Administrative Commission false. I think not. Again this is why Roy Keezel is a third rate lawyer. He does not understand the difference between facts and allegations, hearsay and speculation and out right lies.

In the course of these accusations, she slandered numerous persons,

> Which people? What slander?

caused hurt feelings

> Which people had hurt feelings?

and discouraged participation in worship.

> Who did not attend church because of JW?

She told numerous untruths.

> What untruths?

Despite evidence to the contrary, she continued and continues to make such accusations of wrongdoing.

> What accusations and what wrong doing is Keezel talking about?

When confronted with these facts and conclusions,

> What facts? Conclusions are nothing more than opinions. Again this is why Keezel is a third rate lawyer.

she agreed that the accusations she made were without basis in fact but she refused to recant or apologize.

> Which accusations? Where is the proof that JW agreed with anything. Where is the evidence? Where are the facts? Where is the beef?

More specifically, Joyce Wolter stated words to the effect that Joe Delgatto, Charlie Windham, Walter Ellis, Patty Ellis, Madeline Delgatto, Art Greer, Lynn Johnson and Belinda Windham conspired to involve Heights Presbyterian Church in Independence Heights project whereby the church was exposed to financial ruin and made a participant in a project in a depressed and crime ridden area of Houston without the knowledge or approval of the church.

> Where is the evidence of these statements? Where is the recording or documentation of these stated words.? Joe Delgatto testified to these matters in open court where he admitted to lying to the congregation. The Book of Order was not followed. Charlie Windham did not have authority to sign off on the project as a sole trustee. Again few of the HUD documents have been produced but Delgatto, Windham and Walter Ellis’s names are on those documents. Art Greer, Lynn Johnson and Belinda Windham have backed up Delgatto’s self admitted illegal acts and lies.

> The project is in one of the highest crime areas in the city of Houston as reflected by police reports and numerous articles in the Houston Chronicle. So this is true.

> There has never been any approval by the congregation of the project as is required by the Book of Order. So this is true.

> The financial statements produced by the Administrative Commission do not balance and show a missing $100,000 between 1997 when Delgatto arrived at HPC and 1999. The best evidence of a lack of corruption and financial ruin are the actual financial records which the Administrative Commission refuses to produce for inspection.

She stated that their acts are contrary to Holy Scripture and Presbyterian policy.

> They are contrary to the Book of Order G-8.0501 and G-7.0402. Investment in property must be submitted by the session to the Presbytery, approved by Presbytery and sent back to the session to be followed by a congregational vote. None of these things happened. The corrupt Administrative Commission finalized a commitment to the Independence Heights Project and bypassed the above rules.

Joyce Wolter stated that the above named persons lied about the project to the congregation for two years.

> True. The project was signed off on by Charlie Windham and Joe Delgatto in May 2001. The congregation did not know of the project until February 2002. Walter Ellis, Delgatto and others secretly formed the Independence Heights, Inc without knowledge of the congregation in March 2002. And remember, there has never been a vote on the project by the congregation much less an open discussion and the Administrative Commission has still not released all the HUD records on the project to the congregation.

Joyce Wolter stated that these same individuals received funds under the table for their acts.

> That is part of the allegations in the lawsuit and the bank accounts of the conspirators have not been produced which prove these allegation to be false.

She stated that these individuals breached their fiduciary duty as officers of the church.

> Per the procedures dictated in the Book of Order, the IHP was not approved by the session, the Presbytery or the congregation. The Administrative Commission has been the one to make the final commitment to the project without the approval of the session. They did breach their fiduciary duty.

Joyce Wolter attended an open meeting on March 24, 2003, of the Administrative Commission held to seek healing and specifically promised not to use any information gained at the meeting to advance her lawsuit or foment disharmony.

> The meeting was for no purpose but to have Reagan Brown read the March 24, 2003, interim report regarding the IHP. The session members were not allowed the speak. And the meeting violated the court’s December 6, 2003, injunction regarding discussion of the IHP without John WorldPeace present. Roy Keezel participated in that meeting and will be sanctioned as an attorney for violating the court’s order in due time. Nothing in that meeting was discussed that was not in the interim report which was made available to the congregation. Keezel has not show any evidence of where the report was used to advance the lawsuit nor any evidence of disharmony that was not created by the report itself.

Her son acting as her lawyer, issued motions in her State court reflecting the subject matter of the meeting in violation of her agreement.

> Where are the alleged motions? The interim report was made public. The interim report was the substance of the meeting. There were almost 20 people at the meeting. There is no evidence as to exactly who told WorldPeace what went on in the meeting. Thirty five members of the church filed accusations against the minister. Keezel and others continue to focus on JW when the truth is that half the congregation is in line with JW and against the IHP. This is why the Administrative Commission refused to allow the congregation to vote on the project. They knew it would be defeated and rejected.

She admitted to doing this act and denied that she had taped the meeting.

> Where is JW’s admission? Where is the proof? Where is the evidence? Where is the proof and evidence that JW taped a meeting whose substance was part of the public record given to the congregation?

Joyce Wolter has either caused or supported her son, John WorldPeace, to video tape church services at Heights Presbyterian Church and to hold meetings of her supporters in the sanctuary following the Sunday morning worship service.

> This is WorldPeace’s doings not JW. Those meetings were well attended by over half the active congregation. There is no law, church or otherwise, against taping church services. What Keezel objects to is the fact that WorldPeace has a video tape of Keezel and Delgatto undeniably closing the membership of the church. Without the tapes, the corruption of individuals like Keezel would be nothing but hearsay. This is what Keezel really objects to. In addition, there is a tape of Lynn Johnson lying to the congregation about the authority of the Administrative Commission per the Book of Order. The Rule quoted by Johnson form the pulpit did not authorize the Administrative Commission. Tapes also reflect the lies that Delgatto has made from the pulpit regarding several matters and not just the IHP. A tape shows that Mike Cole undeniably has barred WorldPeace from reactivating his membership at HPC.

The members, the pastor and the Administrative Commission have requested that the taping stop and that there be no further rump meetings held in the sanctuary after services.

> The church is supported by the congregation. It is their sanctuary and Delgatto or anyone else is not in a position to deny the congregation the use of their own sanctuary and church facilities. Where in the Book of Order does Delgatto or anyone else have the authority to stop the congregation from using the sanctuary that it built and maintains. Benny Grable, a congregation member also tapes in the sanctuary. And further, due to the potential violence of the Grables and others, taping cuts down on the conflict.

Such actions continue and Ms. Wolter told the group assembled at her house that she had the ability to stop such but would not.

> Not true. JW cannot stop WorldPeace from taping the Sunday services.

Mr. WorldPeace has done the taping and held the meetings under the guise of supporting her lawsuit until he was disbarred as an attorney.

> This is an absolute lie by Keezel. WorldPeace has not been disbarred. Again it is another example of the third rate nature of Keezel’s ability as an attorney. WorldPeace is still actively practicing law even as he writes this response. Where is the proof that WorldPeace has been disbarred? Keezel is a liar period and this whole accusation is a lie.

He has continued to video tape or cause it to be done.

> Well since WorldPeace is doing the taping, what does this have to do with JW? And since WorldPeace has been barred from membership by Keezel, the Administrative Commission, Mike Cole and Joe Delgatto all of which is a rejection of Christ and a scandal on the gospel per G-5.01033 of the Book of Order, no one in the church has any authority to make WorldPeace do or not do anything other than the civil courts. Again I point to Keezel’s lack of understanding of the civil as well as the church law.

Ms. Wolter has stated in my presence that she does not contribute to the financial needs of the church and that she encourages others to withhold support.

> Actually it is WorldPeace who has encouraged members to withhold monies from the church because as was proven with in September, the Administrative Commission cannot and will not account for the monies that the members contribute to the church. Until there is an accounting, it is foolish for members to pay more money into the church to be potentially misappropriated by the Administrative Commission of which Keezel is a member.

> And if the lying Keezel will go into the Narthex of HPC he will see JW’s name on a plaque for those who contributed significantly to the building of the sanctuary fifty years ago when Keezel was stealing change out of his mother’s purse.

Ms. Wolter has encouraged other members and perhaps herself to disrupt the peace and harmony of the church by making outrageous charges against others and demeaning their acts and intentions.

> OK, here we go again. Which members? What acts disrupted the peace and harmony of the church? What outrageous charges against what others and what demeaning of whose acts and intentions? And how do you demean someone’s intentions anyway? This is why Keezel is not successful in the court house and has a marginal law practice. In fact, so marginal you could say that he practices law as a hobby. He asked my wife not to fax him because he could not afford to pay for the faxes he receives.

These action have gone unabated for some months or years.

> What actions have gone unabated? And by the way, JW has been an active member of the church for over six decades. Keezel is not been involved but for seven months. And the lawsuit is only seventeen months old and so that does not qualify as several years. The only thing Keezel can testify to is what has happened in the last seven months, everything else is hearsay. All Keezel can testify is to the conspiracy of lies that the Administrative Commission has tried to foist on the congregation.

According to interview, she has disrupted the operation of the session and the church to suit her ends.

> Give me a break. Is Keezel saying that he has evidence that JW has nothing better to do that happily create dissension in the congregation? And I suppose this has been going on for over sixty years? So when did she disrupt the session or the church?

If a disciplinary case is prosecuted, these actions might be added to the ones I have outlined.

> What actions might be added? Who knows what Keezel is talking about?

Many members of the church have spoken at meetings and interviews and expressed their despair at the actions of Ms. Wolter.

> Which members? Which meetings? Everyone involved in this process knows the congregation is split in three parts. One for JW, One against and One in the middle. Go to any congregation and find any member that some of the other members do not like. Such is life.

She is not supportive of the pastor, the session or the church.

> The pastor by his own admission in open court is a liar. She is with the minority on the session, so what? But to say that after sixty years of active service, she is not supportive of the church is nonsense. Especially coming from a third rate lawyer who has only been involved in the church for seven months.

I request that an investigative committee be appointed to consider this complaint and that the Commission prosecutes these matters to allow the church to function without the disruptions and hurt directly and indirectly caused by Joyce Wolter.

> What disruptions? What hurt? More generalized rambling by a third rate lawyer.

The Administrative Committee has a file that contains documentation to support the above.

> Well it is Roy Keezel who filed the complaint. What documents are relevant? What documents are not hearsay? Where are these documents? And by the way, is Keezel trying to say that JW is the only problem at HPC and that if she is disciplined that all the lies that the Administrative Commission has told, and the lies that Delgatto has told will disappear into the vapor? The problem at HPC is the corrupt and lying minister and his coconspirators and the Administrative Commission made up of other liars like Keezel and Mr. Hirling who also lied from the pulpit just a few weeks ago. The solution is Joyce Wolter acting in her capacity as trustee per the Book of Order and shining the light on the corruption of people like Delgatto, Cole and Keezel and Hirling.

It also has a tape made with Ms. Wolter's permission that is being transcribed.

> And when was that tape made? And who made it? And why would a tape be made? I thought only WorldPeace made tapes and sometimes Benny Grable? And of course, JW needs this tape and it is to be given to her by the investigating committee per the Book of Order.

Roy <the accuser, the one without sin who casts the first stone>

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