RECONSTRUCTIVE JUSTICE: MISSOURI BAPTIST HEART OF INTEGRITY QUESTIONS

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Originally posted on August 18, 2008,
these questions were originally intended to be
asked of the individuals listed in the
Missouri Baptist Convention
EMERGENCY MEETING PRESS RELEASE

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MISSOURI BAPTIST HEART OF INTEGRITY QUESTIONS
The Role of the Law at a Christian University
~The Government, the Church, and the Law~
(SECTIONS A, B and C)

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Section A

~Southwest Baptist University and The Law~

(Questions 1-7)

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Question 1 (3 parts)

a) As employees and administrative personnel of a Christian institution, are you and your colleagues subject to and obligated to obey the laws of the local, state and federal governments?
Yes/No


b) Is it the moral or ethical obligation or the legal responsibility of you or any other SBU employee to report potentially injurious or serious criminal activity among the SBU staff, associates or supporters to the proper authorities?
Yes/No


c) In your opinion, is there any occasion when possible criminal or unethical conduct by SBU personnel which has resulted in injury or substantial or recurrent harm to others should be concealed from the proper authorities?
Yes/No


Question 2 (16 parts, a - p)
2. If a SBU official, administrator, faculty or staff member, employee or agent had engaged in any of the following illegal or unethical activities, in your opinion, would this be GROUNDS for DISMISSAL from Southwest Baptist University and/or NOTIFICATION of the proper governmental, professional, or church authorities or regulating agencies?

a) Complicity or participation in FORGING
or altering medical, academic, and/or other
RECORDS in order to conceal previous
wrongdoing by the SBU administration or
staff.
Yes/No

b) The presentation of false, misleading, or
incomplete testimony or information during
the discovery process or civil DEPOSITION.
Yes/No

c) The distribution of FALSE, misleading, or
incomplete INFORMATION to local, state, or
federal governmental OFFICIALS in the investigation
of a civil or criminal complaint against SBU, its
agents, employees, or associates with the intent
of defaming or defrauding other individuals or
concealing unethical or criminal conduct by
SBU associates.
Yes/No

d) The threatening of RETALIATION (harm to an
individual's academic career, employment, reputation,
family or friends) against an individual if that person
discussed or revealed illegal or unethical wrongdoing
by SBU faculty, administration, employees, or associates.
Yes/No

e) The continual indoor daytime (during business
hours) "fanspray" application of dangerous,
now-banned pesticides by an UNCERTIFIED
applicator on the SBU campus while students
were present.
Yes/No

f) The continual indoor daytime (during business
hours) "fanspray" application of dangerous,
now-banned pesticides by an UNCERTIFIED
applicator on the SBU campus while students
were present--even AFTER several students had
reported injuries and at least one was acutely
exposed twice and permanently disabled.
Yes/No

g) The purposeful DISREGARD of a PHYSICIAN'S
written INSTRUCTIONS which resulted in detriment
and injury to a student's health.
Yes/No

h) Complicity or participation in the use of
ADMINISTRATIVE AUTHORITY in the
orchestrated DEFAMATION of individuals
in order to DISCREDIT those individuals
and CONCEAL potentially criminal wrongdoing
by the SBU administration, employees, or
supporters.
Yes/No

i) The illegal use of ADMINISTRATIVE AUTHORITY
to discuss or distribute (without the student's
authorization) the confidential academic, medical,
or personal RECORDS of a SBU student with
a student's employer(s), friends or coworkers,
church personnel, deacons, church members,
or other unauthorized individuals.
Yes/No

j) The illegal use of ADMINISTRATIVE
AUTHORITY to discuss or DISTRIBUTE FALSE,
fabricated, misleading or incomplete INFORMATION
or documentation about a student with the student's
employer(s), friends or coworkers, church personnel,
church members, deacons, or other unauthorized
individuals with the intent of discrediting, defaming
or DEFRAUDING a student.
Yes/No

k) The searching and intentional VANDALISM
of a student's room and personal belongings for the
purpose of debasing the student and FORCING
the student to leave the University.
Yes/No

l) The PHYSICAL MENACING, harassment,
coercion, hazing, or INJURY of a student or
other individual(s) -- both on and off campus.
Yes/No

m) Complicity or participation in the recurrent,
prolonged and PREDATORY SEXUAL HARASSMENT
and defamation of students (even AFTER the
students left the SBU campus).
Yes/No

n) The persistent or retaliatory use of defamatory,
incendiary, or demeaning terms by the SBU
staff, faculty, and administration, such as:

*"CRAZY" -- a person who disagrees with the
SBU administration, staff, or policies;

*"DEMONIC" or "demon-possessed" -- a person
who is ill or who has experienced health problems;

*"HEATHEN" -- a student or other person who
does not currently attend church;

*"LIAR" -- a person, particularly a student,
who expresses opinions which threaten the
"status quo" or are different from those of
the SBU administration, staff, or associates;

*"MOOCHER" -- a person who accepts hospitality
from a Christian, or who asks for assistance from a
church or church-related organization during a crisis;

*"N****R" -- a black or dark-skinned person;

*"N****R-LOVER" -- someone who has friends
who are black or dark-skinned;

*"PAGAN" -- a non-Baptist Christian, or a member
of any other religious community.

*"W***E" -- virtually any unmarried woman,
virgin or not, or a divorced women;

*"PERVERT" -- a person who has experienced
sexual confusion or abuse, is or was sexually active,
or anyone who cares about or associates with
such persons;

*"PROBLEM STUDENT" -- a student who
disturbs the normal routine by expressing new
viewpoints or challenging the SBU administration,
staff, or associates;

*"PSYCHO" -- a student or other person who
causes the SBU staff, administration, or associates
to be inconvenienced;

*"QUEER" -- an effeminate male; or an unmarried
female, esp. one who is not dating or is not sexually
active, or a person who was reluctant to take part in
unseemly or coarse joking and discussions or would
not submit to groping or molestation by the SBU
administrative staff.

*"ROGUE CHRISTIAN" -- a Christian who, due
to severe disability or health problems, is unable
to attend church.
Yes/No

o) Complicity or participation in the use of
ADMINISTRATIVE AUTHORITY to PROPAGATE
malicious and unfounded rumors and FALSE
ACCUSATIONS (which resulted in profound
disruption to the student's family, social,
financial, emotional, academic, and spiritual
life) in an attempt to SHIELD SBU from LEGAL
LIABILITY and potential embarrassment in
the previous and now-acknowledged SEXUAL
MISCONDUCT of several SBU staff and
administrators.
Yes/No

p) The persistent misleading and conscious DECEIT
of University officials resulting in SUBSTANTIAL
and REPEATED physical, psychological, emotional
or spiritual HARM to other individuals.
Yes/No

Question 3 (16 parts, a - p)
3. If a SBU instructor, administrator, employee, or supporter had engaged in any of the above illegal or unethical activities, in your opinion, should that individual qualify for SPECIAL TREATMENT from Southwest Baptist University, the Missouri or Southern Baptist Conventions, any governmental agencies, institution or individuals (supporters, Trustees, Regents, or contributors) associated with Southwest Baptist University in the form of: promotions, tenure, pay raises, special bonuses ("housing allowances," etc.), ceremonial awards or recognition (Life Beautiful Award, career achievement award, etc.), political or church-related positions, financial remuneration and gratuities, or any other considerations?


Please answer Yes/No to the above 16 items (a - p) in Question 2.


Question 4
4. If a SBU administrator, member of the faculty or staff, or other SBU employee or associate were found to have committed an illegal or unethical offense against a student, in your opinion, does the SBU GOVERNANCE bare the ethical RESPONSIBILITY for reconciling the situation by determining suitable and timely disciplinary action against the employee or associate and providing amends or compensation for the wronged student?
Yes/No


Question 5
5. If a SBU administrator, member of the faculty or staff, or other SBU employee or associate were found to have committed an illegal or unethical offense against a student, in your opinion, during what TIME FRAME should the governance of Southwest Baptist University provide the student with an apology, compensation, amends, correction of the student's record, restitution, reconciliation, or other appropriate response?


Please indicate Yes to one of the following (a - l):

a) within one day
b) within one week
c) within one month
d) within six months
e) within one year
f) within two years
h) within five years
i) within ten years
j) within twenty or more years
k) not until the student dies
l) SBU has no ethical obligation to apologize
or offer amends for the criminal or unethical
conduct of its employees, officials, or associates.

Question 6
6. In your opinion, if the SBU administration and governance, having been alerted on numerous occasions of the possible illegal or unethical conduct of a SBU administrator, member of the faculty or staff, or other SBU employee or associate, failed to take substantive and decisive action to rectify the situation and prevent further incidents in the future, would this indicate the failure of administrative authority and precipitate the REEVALUATION of the legitimacy, effectiveness, and INTEGRITY of the SBU governance?
Yes/No


Question 7 (3 parts, a - c)
a) In your opinion, are the SBU Trustees and the members of the leadership of the Missouri Baptist Convention (which owns SBU), as individuals, LEGALLY, MORALLY, and FINANCIALLY liable for the administrative policies and activities of Southwest Baptist University and its employees and agents?
Yes/No

b) As a member of the SBU staff or administration, do you condone (or have you ever condoned) the use of SLANDER, INTIMIDATION, physical assault or VIOLENCE against any individuals who disagree with the policies or behavior of SBU personnel?
Yes/No

c) Do you believe that the CAREER, REPUTATION, HEALTH, or LIFE of any individual should be FORFEITED in order to COVER the illegal, fraudulent, and/or potentially costly or embarrassing misconduct of the officials, employees, or associates of Southwest Baptist University, or the Missouri and Southern Baptist Conventions?
Yes/No

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WARNING: These questions contain
direct and indirect references
to sexual information and discussion,
and, as such,
this material is not suited or intended
for younger or sensitive readers.

PLEASE READ WITH CAUTION!

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The majority of this information has been available
to Southwest Baptist University --
in the form of hundreds of pages
of Interrogatories and affidavits --
since December 1993 - September 1997.

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Section A/Question 8:
~Southwest Baptist University and The Law~
Definition of Terms --
Predatory Harassment, Sexual Harassment, and Defamation
Question 8 (a - w)

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Section A

~Southwest Baptist University and The Law~

(Question 8)

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Question 8 (23 parts a-w)
8. In your opinion, would participation or complicity in any of the following actions (described in a - w) by SBU administrators, faculty, staff, or associates CONSTITUTE unethical or illegal PREDATORY HARASSMENT, SEXUAL HARASSMENT, or DEFAMATION of a student?

a) The recurrent endeavor by a married Southwest
Baptist University administrator (a former high
official of the Southern Baptist Convention) to
TOUCH, FONDLE, or MOLEST several female
work-study students -- in spite of the students'
(plural) complaints about the administrator's
inappropriate contact?
Yes/No

b) The demand by a SBU administrator that a female
work-study student -- who had made a complaint
against the administrator's advances -- concede to
being reassigned as his "personal secretary" or be
forced to resign from the work-study program?
Yes/No

c) The RECURRENT endeavor by another married
Southwest Baptist University administrator to
PHYSICALLY and SEXUALLY intimidate, menace,
demean, and humiliate a student.
Yes/No

d) The use of ADMINISTRATIVE AUTHORITY
to DEMAND that a female student, in order to
continue at the university, must submit to FORCED
COUNSELING (which would become part of her
permanent record), because the student's actions
in DECLINING the SEXUAL ADVANCES and
REPORTING the sexual misconduct of several older,
married men -- including two SBU administrators
and a pastor -- indicated, in his view, that the student
was "over-reacting" and "not able to show Christian
affection," which was the result of "unnatural
affections" and "probable homosexual tendencies."

*The student in this case refused to the FORCED
COUNSELING. The administrators and pastor in
question were later forced to confess to sexual
misconduct and abuse of authority with other
young women, including multiple instances of
adultery, and, reportedly in one case, incest.
Yes/No

e) The DEMAND by a SBU administrator that a
student would face EXPULSION (and a record
of the disciplinary action in her permanent
academic record) if she did not act as an
"informant" and PROVIDE INFORMATION on
the sexual activities and histories (including
childhood abuse) of her dormmates, friends,
and other SBU students, so that he could
"discern" which students, especially "smart
women," were likely to be used as "instruments
of the devil," and involved in "wh**edom" or
"Satan worship."
Yes/No

*After explaining that she had NO first-hand
knowledge of ANY student's sexual activities
and did not intend to break trust with friends
and prayer partners by discussing confidential
matters, the student in this case refused to act
as an "informant," and was, as a result, told that
she was expelled, effective immediately, and was
dismissed to go pack. However, no formal
administrative action was actually taken
against her.

f) The ABUSE of ADMINISTRATIVE AUTHORITY
by the DEMAND by a SBU administrator that
a female student would be EXPELLED (and the
disciplinary action for "insubordination" placed
in her academic record) if she did not immediately
answer his summons and come to his office to
sit facing him, as he sat on the desktop (with
his legs apart and often fully aroused) with the
student's face inches from his crouch, as he
recited (in increasingly graphic and obscene
detail) the list of sexual sins, which his ever-
secret "sources" reported as having been
committed by the student and her classmates --
until the student finally broke down in tears
and begged to leave, which the administrator
affirmed as "proof" of the student's "guilty
conscience."
Yes/No

*After several semesters of such encounters,
the student in this case refused to answer the
administrator's written summons, telling the
Resident Assistant and Dorm Mother the reason
for her refusal and explaining that, in the future,
she would push the letters out of the back of
her campus mailbox -- without opening them.


g) The abuse of ADMINISTRATIVE AUTHORITY
to engage in RETALIATORY SLANDER (by the
distribution of FALSE and malicious accusations
based on no evidence, fabricated events and
fictitious "witnesses") to a student's parents,
friends, employers, and other church members
that a female SBU student was "promiscuous"
and, therefore, UNWORTHY to pursue a career
in the ministry.
Yes/No

h) The abuse of ADMINISTRATIVE AUTHORITY
to engage in RETALIATORY SLANDER against
a female SBU student by distribution of FALSE
accusations to a student's parents and others
that a SBU student was "promiscuous" and,
therefore, UNWORTHY to pursue a career in
the ministry -- even though the student had not
dated, was unquestionably qualified as a virgin
(by any definition), and had obtained MEDICAL
PROOF of her virginity.
Yes/No

i) The use of ADMINISTRATIVE AUTHORITY to
ENCOURAGE the sexual harassment of a SBU
student by other students, especially members
of the male sports teams -- including a violent
but unsuccessful, on-campus, homosexual assault
against a student with the intent of forcibly and
"manually" DESTROYING the proof of a student's
virginity.
Yes/No

j) The abuse of ADMINISTRATIVE AUTHORITY
by engaging in RETALIATORY SLANDER by
means of the distribution of FALSE ACCUSATIONS
to a student's parents and others that a SBU
student -- who had stated that she would defend
herself, if necessary, against any further sexual
assault -- was, for this reason, "unstable," "violent"
and "possibly dangerous" and should not be
permitted to return home to her family or to her
home church, or to pursue a professional career
involving the ministry or working with children.
Yes/No

k) The use of ADMINISTRATIVE AUTHORITY
to engage in RETALIATORY SLANDER (after
the student had quietly reported her concerns
about the misconduct of several administrators
and a pastor) by the circulation, without the
student's knowledge, of FALSE ACCUSATIONS
to SBU staff members, Bolivar townspeople,
and others that a SBU student had been a
PROSTITUTE and had left campus to have
an ABORTION and/or a CHILD.
Yes/No

l) The abuse of ADMINISTRATIVE AUTHORITY
to engage in RETALIATORY SLANDER by
calling a student's PARENTS on the day before
her mother was to have major surgery to inform
them (without providing evidence or witnesses,
or allowing the student an opportunity to confront
her accusers, or to defend herself against the
allegations) that the student was ENGAGED
in PROSTITUTION and ALCOHOL and DRUG
ABUSE.
Yes/No

m) The ABUSE of ADMINISTRATIVE AUTHORITY to
deceptively (and illegally) gain access to a student's
personal belongings, personal papers, diaries, and
research/study notes in order to SEARCH and
vandalize her room as a means of intimidating,
humiliating, and vindictively DEBASING the student.
Yes/No

*The student in this case was told (in writing)
that she was a "problem student" (with no
explanation or reason given for this use of this
term) and must leave campus housing, which
she did, immediately.

n) The ABUSE of ADMINISTRATIVE AUTHORITY
by engaging in RETALIATORY SLANDER based
on the DELIBERATE MISINTERPRETATION
of the student's (illegally seized and vandalized)
research notes by claiming that the student was
NOT initially researching an academic paper
(which later developed into the writing of a
Medieval historical novel), but was a WITCH,
who had been cutting up animals and offering
BLOOD SACRIFICES to Satan in the park,
and should, therefore, be denied church
fellowship [the administrator was a deacon
at her local church] and the opportunity to
complete a degree program at a Christian
university.
Yes/No

o) The ABUSE of ADMINISTRATIVE AUTHORITY
through the engagement of the retaliatory
PSYCHOLOGICAL, EMOTIONAL, and SOCIAL
ABUSE by the systematic disruption of a SBU
student's friendships with classmates and the
REFUSAL to grant PERMISSION to other SBU
students to ROOM with the student in off-campus
housing based on the RETALIATORY SLANDERS
that the student was: "promiscuous"; had been
a prostitute; had an abortion and/or child, and,
later, was "unstable," "violent," "antisocial," "a
witch" and "NOT a suitable Christian student."
Yes/No

p) The abuse of ADMINISTRATIVE AUTHORITY
to engage in RETALIATORY SLANDER by the
propagation of false accusations to a student's
EMPLOYER and the ENCOURAGEMENT
and/or TOLERANCE of sexual humiliation,
slander, and harassment against the student.
Yes/No

q) The ABUSE of ADMINISTRATIVE AUTHORITY
to engage in the retaliatory PSYCHOLOGICAL
and EMOTIONAL ABUSE by the DEMAND to
the student's parents and pastor that, in order
to graduate from Southwest Baptist University,
the student must CONFESS to substance abuse
and submit to FORCED DRUG and ALCOHOL
COUNSELING (which would become part of
her permanent academic record) -- in spite of
the fact that there was never ANY evidence of
or witness to ANY substance abuse whatsoever
and that the student had agreed to undergo
drug testing and/or monitoring to prove her
innocence.
Yes/No

*The student in this case refused to confess
or submit to counseling, was told that she was
once again expelled, but no formal administrative
action was taken.

r) The ABUSE of ADMINISTRATIVE AUTHORITY
by using leadership position within the local church
(such as deacon, pastors, Sunday school teachers,
etc.) to engage in RETALIATORY SLANDER and
the spread of vindictive misinformation for the
purpose of DISRUPTING a student's CHURCH and
SPIRITUAL LIFE -- even extending to the circulating
slander to pastors and members of other churches,
which the student sought to join or visit in Bolivar,
Polk and Greene Counties and even out-of-state --
and preventing the student's pursuit of a career
in the Christian ministry or teaching.
Yes/No

s) The ABUSE of ADMINISTRATIVE AUTHORITY
and PASTORAL AUTHORITY to distribute (in
violation of FERPA) a CONFIDENTIAL LETTER
sent to a pastor closely associated with SBU and
the circulation of retaliatory slander based on the
DELIBERATE MISINTERPRETATION of that letter.
Yes/No


t) The ABUSE of ADMINISTRATIVE AUTHORITY
to engage in the retaliatory PSYCHOLOGICAL
and EMOTIONAL ABUSE by the demand that,
in order to complete a degree at SBU, a senior
student must submit to FORCED COUNSELING
(which would become part of her permanent
academic record) and CONFESS her parents'
participation and "guilt" in UNREMEMBERED
"CHILDHOOD ABUSE," which the administrator
declared was at the root of the student's "sexual
inadequacy and sin," "rebellion," and inability to
"repent and cooperate" with his "investigations"
of the childhood abuse and sexual activities of
other students.
Yes/No

u) The ABUSE of ADMINISTRATIVE AUTHORITY
by the deliberate retaliatory PSYCHOLOGICAL
and EMOTIONAL ABUSE of a SBU student by
the circulation of the SLANDER that her HEALTH
DIFFICULTIES were directly due to her "sexual sin
problem," the result of the "WRATH OF GOD" and
her "sins of omission and commission" in refusing
to confess and to cooperate with his "investigations."
Yes/No

v) The USE of ADMINISTRATIVE AUTHORITY to
engage in the malicious distribution of CONFIDENTIAL
MEDICAL HISTORY with the purpose of denigrating
a student and dissuading or preventing the student
from pursuing a professional or ministerial career.
Yes/No
and
The CONTINUED distribution of MEDICAL
INFORMATION -- even AFTER such information
was shown to be FALSE and INACCURATE --
in order to FURTHER discredit, harass, and
intimidate the student.
Yes/No


w) The USE of ADMINISTRATIVE AUTHORITY
to inflict PSYCHOLOGICAL and EMOTIONAL
ABUSE upon a distraught SBU student by
meticulously illustrating the techniques used
to SUCCESSFULLY COMMIT SUICIDE, taunting
the student with the rationality that -- since it
was now impossible to prove her innocence
of the dozens of false accusations and
RETALIATORY SLANDERS circulated by the
SBU administration, staff and others, and,
given the fact that "a decent, Christian man"
would not marry her "with such a bad reputation,"
and that she would never have a family, or have
a professional career in teaching or the ministry
"with such a bad record" -- it was best that the
student CONFESS her sins "while God could
still forgive" her and "go home to be with the
Lord," so she would not selfishly burden her
family and friends with any more disappointment,
trouble, or hardship.
Yes/No

*The student in this case eventually sought counseling on her own from a professor, who agreed that, after all the abuse and harassment, the professor would be saddened ("but not at all surprised") if the student did, in fact, end her life "just to find some peace."

However, the professor warned that if the student stayed at the university, the administrator, if given the opportunity, would, in order to silence her, have her involuntarily committed for having taken his "advice" in contemplating suicide.

The student left Southwest Baptist University mid-semester -- without funds, alienated from her family and home church, suffering from ill health, and having no where to go.

Wanting to escape the relentless persecution of the administrator (who was a deacon at the church), she resigned from that local church, stating that she no longer wanted to have anything to do with institutional Christianity.

This student does not regret that decision, as leaving SBU and the institutional church saved her soul ... and gave her a new life.

Yes, the student had a new life -- at least until she returned to Southwest Baptist University (following the sudden dismissal one of the primary persecuting administrators/ deacons for adultery and sexual misconduct) to finish her few remaining classes and complete her degree at a Christian university, which was her father's dying wish.

Less then a month into the semester, while attending class on the campus of Southwest Baptist University, the student was acutely poisoned and permanently disabled by illegally- applied, neurotoxic pesticides.

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Section B:
~The Government and the Law~
Questions 9-22

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Question 9
9. Have you ever stated or implied or do you know of any statement or implication by any SBU Trustee, employee or supporter, past or present, that the pesticides used on the SBU campus were "NONTOXIC," "SAFE," or "SAFE WHEN USED AS DIRECTED."*
Yes/No

*In recognition of the hazards to human health, it is a violation of federal law to claim that pesticides are "nontoxic," "safe," or "safe when used as directed." [Federal Insecticide Fungicide and Rodentcide Act (8)].

Question 10
10. Did you participate or are you aware of any instance in which an individual's academic or medical DOCUMENTATION was FORGED, fabricated, altered, deliberately CONCEALED or "lost" by individuals associated with SBU or Campbell Pest Control.
Yes/No

Question 11
11. Did you participate in or do you have knowledge of any possible attempt to OBSTRUCT JUSTICE in a civil or potential criminal proceeding against SBU or Campbell Pest Control by the fabrication, alteration, concealment, or destruction of DOCUMENTATION concerning pesticide applications at SBU and those individuals injured by or exposed to these pesticides?
Yes/No

Question 12
12. Have you participated in or are you aware of any THREAT and/or ACT of RETALIATION AGAINST the FAMILY or FRIENDS of individuals who requested information on the pesticides used at SBU or who offered to assist anyone injured by or exposed to those pesticides?
Yes/No

Question 13
13. Are you aware of any instances in which SBU employees or supporters have DISTRIBUTED or DISCUSSED (without a student's authorization) the confidential academic, medical, or personal RECORDS of a SBU student or alumnus with a student's employer(s), friends or coworkers, church personnel, church members, deacons, or other individuals? *
Yes/No

*Federal laws (including FERPA, the Federal Educational Right to Privacy Act) protect the privacy rights of students to records and information kept by institutions of higher education. Disclosure and discussion of this information without the authorization of the student is a criminal act.

Question 14
14. Did you participate in or do you have knowledge of any possible endeavor to OBSTRUCT JUSTICE by attempting to INFLUENCE potential WITNESSES in a civil or potential criminal proceeding against Southwest Baptist University (SBU) or Campbell Pest Control by the DISTRIBUTION of patently false, fabricated, misleading, or grossly distorted medical and/or personal information, documentation, and RECORDS about any individual?
Yes/No

Question 15
15. Did you participate in or do you have knowledge of any possible endeavor to OBSTRUCT JUSTICE by attempting to INFLUENCE POTENTIAL WITNESSES in a civil or potential criminal proceeding against the Missouri Baptist Convention, SBU or Campbell Pest Control by the promise of REWARD, SPECIAL TREATMENT or FAVOR in the form of: promotions, tenure, pay raises, special bonuses ("housing allowances," etc.), ceremonial awards or recognition (Life Beautiful Award, career achievement awards, etc.), political or church-related positions, financial remuneration and gratuities, or other considerations in return for misleading, false, slanted or tainted testimony or silence regarding the known illegal misconduct of the governance, employees, or associates of Southwest Baptist University?
Yes/No

Question 16
16. Have you participated in or are you aware of any instance in which deceptive, false, misleading, fraudulent or illegally obtained verbal information or documentation was presented *to* or *by* any INSURANCE AGENT associated in any way with Southwest Baptist University or Campbell Pest Control?
Yes/No

Question 17
17. Did you provide or do you have knowledge of the provision of any false, deceptive, fraudulent or misleading verbal, documentary, or written information to any AGENT of the Missouri Department of AGRICULTURE by individuals associated with Southwest Baptist University or Campbell Pest Control?
Yes/No

Question 18
18. Did you participate in or are you aware of any instance in which individuals associated with SBU or Campbell Pest Control provided false, deceptive, fraudulent, or misleading verbal information or documentation to any AGENT of a local GOVERNMENTAL or COMMUNITY AGENCY including, but not limited to: the Polk County Sheriff's Department, the Bolivar City Police, the Bolivar Board of Alderman, the Polk County Community Center, the American Red Cross (Joplin, Missouri), and the Ozark Area Community Action Corporation (OACAC) of Springfield, Missouri?
Yes/No

Question 19
19. Did you participate in or are you aware of any occurrence in which individuals associated with SBU or Campbell Pest Control provided false, deceptive, fraudulent, deliberately incomplete or misleading verbal information or documentation to any AGENT of the STATE of MISSOURI including, but not limited to: the Missouri Department of Education, the Missouri State Board of Nursing, the Missouri Department of Insurance, the Polk County Division of Family Services, the Polk County Division of Aging (Bolivar), the Greene County Department of Social Security, or the Empire District Electric Company (regulated by the Missouri Public Service Commission)?
Yes/No

Question 20
20. Did you participate in or are you aware of any occurrence in which individuals associated with Southwest Baptist University or Campbell Pest Control provided false, deceptive, fraudulent, deliberately incomplete or misleading verbal information or documentation to any AGENT of the FEDERAL GOVERNMENT of the UNITED STATES, including but not limited to: the Environmental Protection Agency (EPA), the federal Department of Education, the Department of Education (Accreditation and Eligibility Determination Division), North Central Association of Colleges and Schools (NCA), or the Department of Education Student Financial Assistance Programs, Region 7 (NDSL).
Yes/No

Question 21
21. Did you participate in or are you aware of any effort by the SBU LEGAL STAFF, EMPLOYEES, administrative personnel, or supporters to collaborate with local, community or church officials and businesses to illegally OBSTRUCT any pesticide-injured student or other individual from obtaining disability benefits or COMMUNITY/ CHURCH ASSISTANCE (medical, nutritional, or energy) by the harassment and intimidation of the individual's friends and family, the distribution of defamatory, false or misleading information, and/or extortion, coercion, and the threat or act of physical harm?*
Yes/No

*This conduct is potentially criminal under the Americans with Disabilities Act of 1990, SEC. 503.Prohibition Against Retaliation and Coercion, 42 USC 12203.

Question 22 (3 parts, a - c)
a) Are you aware of any effort by the SBU governance or supporters to exert political influence or advocate the use of POLITICAL INFLUENCE through local, state, and federal agencies, officials or courts in order to thwart or QUASH an INVESTIGATION against the Missouri Baptist Convention, Southwest Baptist University, or Campbell Pest Control or silence potential witnesses?
Yes/No

b) Have you participated in or are you aware of any effort by the governance, employees, or supporters of SBU or the Missouri Baptist Convention to encourage or allow the INTIMIDATION of any individual (through the use of slander, psychological harassment, and/or physical assault) in order to CONCEAL the potentially criminal or politically embarrassing misconduct of such a government official, POLITICIAN, political officeholder or candidate?
Yes/No

c) Are you aware of any information concerning the past or current MISCONDUCT of any government official, political officeholder, candidate, or POLITICIAN associated with Southwest Baptist University which, if discovered, would result in criminal or civil penalties and political embarrassment?
Yes/No

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Section C:
~Ethics, The Church, and the Law~
(Questions 23-31)


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Question 23
23. Did you participate in or are you aware of any occurrence in which false, deceptive, fraudulent, or misleading verbal information or documentation was given to any AGENT of any CHURCH-RELATED ORGANIZATION including, but not limited to: the Bolivar Ministerial Alliance, the Polk County Community Center, Springfield Council of Churches (Missouri), the Mid-Lakes Baptist Association (Bolivar, Missouri), the First Baptist Churches of Bolivar and Springfield (Missouri) and Newport News (Virginia), Second Baptist Church of Springfield (Missouri), First Assembly of God Church of Bolivar (Missouri), United Methodist Church of Bolivar (Missouri), the Missouri Baptist Convention, and the Southern Baptist Convention (Nashville, TN).
Yes/No

Question 24
24. Do you have knowledge of any effort by the Missouri or Southern Baptist leadership or by individual PASTORS associated with SBU to exert RELIGIOUS or POLITICAL influence and INTERVENTION in an attempt to thwart, deter, confuse, or interfere with a civil or criminal investigation of employees or supporters of Southwest Baptist University, the Missouri Baptist Convention, or Campbell Pest Control?
Yes/No

Question 25 (a - l, 12 parts)
25. Did you participate in or do you have any knowledge of any INCIDENTS in which pastors, church officials, leaders or employees, deacons, or other church agents associated with Southwest Baptist University, the Southern Baptist Convention, or the Missouri Baptist Convention engaged in, supported, or encourage the following UNETHICAL OR CRIMINAL CONDUCT AGAINST ANY INDIVIDUAL who had made CRIMINAL or CIVIL COMPLAINT against the officials, employees, associates, or agents of Southwest Baptist University, the Missouri or Southern Baptist officials, or employees:

a) The DENIAL of CHURCH MEMBERSHIP or Christian FELLOWSHIP to a SBU student or other individuals.
Yes/No

b) The DENIAL of CHURCH MEMBERSHIP or Christian FELLOWSHIP to the FRIENDS or FAMILY members of a Southwest Baptist University student.
Yes/No

c) The DENIAL or OBSTRUCTION of COMMUNITY and CHURCH ASSISTANCE to a Southwest Baptist University student.
Yes/No

d) The DENIAL or OBSTRUCTION of COMMUNITY and CHURCH ASSISTANCE to FRIENDS or FAMILY MEMBERS of a student.
Yes/No

e) The use of PASTORAL AUTHORITY and prestige to INCITE and FOSTER pernicious ILL-WILL and hostility against a student, the students' family or friends, or other individuals with the purpose of conspiring to DEFRAUD a student or other individual.
Yes/No

f) The use of PASTORAL AUTHORITY and prestige to INCITE and FOSTER pernicious ILL-WILL among other NON-BAPTIST PASTORS to DENY CHURCH FELLOWSHIP or ASSISTANCE to a student or to the family or friends of a student with the purpose of conspiring to DEFRAUD a student or other individual.
Yes/No

g) The VIOLATION of PASTORAL ETHICS by the distribution to unauthorized persons of personal, medical, or other CONFIDENTIAL INFORMATION about a student or other individual (or the family or friends of such individuals).
Yes/No

h) The VIOLATION of PASTORAL ETHICS by the distribution of false, misleading, fraudulent, incomplete, or DEFAMATORY INFORMATION against a student or other individual (or the family or friends of such individuals) with the intention of conspiring to DEFAME, DEFRAUD or INJURE the individual or attempt to conceal the unethical or criminal conduct of Southwest Baptist University employees, agents, and associates.
Yes/No

i) The ABUSE of CHURCH LEADERSHIP positions within the local church by Southwest Baptist University faculty, administration and legal staff to INCITE and NURTURE pernicious ILL-WILL and hostility against a student (or student's family or friends) with the purpose of conspiring to DEFAME, DEFRAUD, or INJURE a student or other individual or attempt to conceal the unethical or criminal conduct of SBU employees, agents, and associates.
Yes/No

j) The ABUSE of CHURCH LEADERSHIP positions within local churches by Southwest Baptist University administration, faculty, associates, and legal staff to distribute false, misleading, fraudulent, incomplete, or DEFAMATORY INFORMATION with the purpose of DEFRAUDING a student or other individual and attempting to conceal the unethical or criminal conduct of SBU employees, agents, and associates.
Yes/No

k) The USE of INTIMIDATION and THREAT by Southern Baptist PASTORS associated with Southwest Baptist University against a student or the friends and family of a student (either verbal or written).
Yes/No

l) The COLLABORATION with local GOVERNMENT officials in an effort to deny a qualified individual CHURCH or COMMUNITY assistance in an effort to DEFRAUD, DEFAME, or INJURE that individual.
Yes/No

Question 26
26. If a pastor, church official, leader, employee, deacon or other agent associated with Southwest Baptist University, the Southern Baptist Convention, or the Missouri Baptist Convention had acted in the manner described in Question 25 (a - l), in your opinion, would this be GROUNDS for the DISMISSAL or DISASSOCIATION from Southwest Baptist University or other substantial censure by the appropriate local church, Missouri Baptist Convention, or the Southern Baptist Convention?

Please answer Yes/No to each item a - l in Question 25.


Question 27
27. If a pastor, church official, leader or employee, deacon, or other church agent associated with Southwest Baptist University, the Southern Baptist Convention, or the Missouri Baptist Convention engaged in any of the above illegal or unethical activities [described in Question 25 (a - l)], in your opinion, should that individual qualify for SPECIAL TREATMENT from Southwest Baptist University, the Missouri or Southern Baptist Conventions, any governmental agencies, institution or individuals (supporters, Trustees, Regents, or contributors) associated with Southwest Baptist University in the form of: promotions, tenure, pay raises, special bonuses ("housing allowances," etc.), ceremonial awards or recognition (Life Beautiful Award, career achievement award, etc.), political or church-related positions, financial remuneration and gratuities, or any other considerations?

Please answer Yes/No to each item a - l in Question 25.


Question 28
28. Did you participate in or are you aware of any effort by PASTORS and CHURCH-RELATED ORGANIZATIONS associated with Southwest Baptist University to DEFRAUD a pesticide-injured student by obstructing the student from obtaining medical, nutritional, or energy ASSISTANCE through local churches or charitable organizations by the distribution of slanderous and intentionally deceitful or misleading information and the COLLABORATION with PUBLIC OFFICIALS to menace, injure, and/or harass the student or the student's friends and family?
Yes/No


Question 29 (6 parts, a - f)
29. Did you participate in or are you aware of any specific instance(s) in which:

a) A Bolivar pastor (a SBU Trustee and prominent leader of the Bolivar Ministerial Alliance) wrote a menacing letter to the friend of pesticide-injured student stating that he would "not tolerate" the friend praying for or discussing the pesticide- injured student in any church gathering, or "publicly broadcasting" information about the (possibly illegal) exposure of SBU students to dangerous pesticides and solvents or criticising SBU, or "the city, the state government, or any other institution?"
Yes/No

b) A SBU Trustee (a Southern Baptist pastor from Bolivar) organized a secret Deacons' Meeting, primarily attended by SBU employees and legal staff, to discuss a SBU student's civil and criminal complaint against various SBU employees and afterwards sent written notice to the student of the decision by the pastor and his deacons (without the benefit of a church vote) to deny the student church membership and fellowship?
Yes/No

c) A local Bolivar pastor (a SBU Trustee and prominent leader of the Bolivar Ministerial Alliance) and other colleges and associates with the director of the POLK COUNTY COMMUNITY CENTER, disparaged and denigrated a pesticide-injured SBU student, and actively encouraged the Director to resist and DENY any efforts to obtain food, energy, medical, or fundraising ASSISTANCE for the student because, though financially qualified and verified as totally disabled by a panel of Social Security physicians, the student had "provoked" Southwest Baptist University by making civil and criminal complaints against SBU and "did not deserve" assistance?
Yes/No

d) A local Bolivar pastor (a SBU Trustee and prominent leader of the Bolivar Ministerial Alliance) and other colleges and associates discussed the electrical bill of a student injured by pesticides at SBU with the manager of Empire District ELECTRIC COMPANY, disparaged and denigrated the student and COLLABORATED with him to resist and DENY any effort by the student (or the student's friends or family) to obtain ASSISTANCE paying the electrical bill because the student, though financially qualified and verified as totally disabled by a panel of Social Security physicians, had "provoked" Southwest Baptist University by making civil and criminal complaints against the university and, therefore, "did not deserve" assistance?
Yes/No

e) A Bolivar pastor (a SBU Trustee and prominent leader of the Bolivar Ministerial Alliance) and other colleagues and associates urged the pastor and his Methodist congregation to DENY the student (who was disabled by pesticides at SBU) the $40 in financial ASSISTANCE, which the Methodist pastor had promised the student, on the grounds that the student was "undeserving" of Christian fellowship or financial assistance, because the student had "provoked" and affronted Southwest Baptist University by making civil and criminal complaints against the university?
Yes/No

f) The out-of-state "home" Southern Baptist pastor of a pesticide-disabled student (after conferring with a Bolivar pastor and SBU associates) indicated that if the student's widowed and disabled mother discussed the civil or criminal complaints against Southwest Baptist University or the exposure of SBU students to dangerous pesticides and solvents, and if her mother continued to support the student's efforts to return home or relocate, he, as the mother's pastor, would see to it that the members of his church refused fellowship, assistance, and support to the student's mother, family, and friends?
Yes/No

Question 30
30. Do you have knowledge of any unethical or illegal actions by any of the legal staff employed by or associated with Southwest Baptist University, the Southern Baptist Convention or the Missouri Baptist Convention which, if pursued and reported to the Missouri Bar Association or any other government or regulating agency, would likely result in the loss of his or her license and the DISBARMENT of that individual from the practice of law?
Yes/No

Question 31
31. If an attorney employed by or associated with Southwest Baptist University, the Southern Baptist Convention, or the Missouri Baptist Convention were found to have engaged in any illegal or unethical activities which defamed, defrauded, or resulted in substantial harm or injury to a student or employee of Southwest Baptist University, in your opinion, would this be GROUNDS for DISASSOCIATION or DISMISSAL from Southwest Baptist University?
Yes/No