The Thirty-one Questions

This is not the entire document --
it is only the Thirty-one (31) Questions
which Marie would like
Dr. David Clippard,
the Executive Director
of the Missouri Baptist Convention,
and
Dr. Bob Curtis
the president
of the Missouri Baptist Convention
and chairman of the Executive Board
of the Missouri Baptist Convention,
and
Pastor Dick Price,
the chairman of
of the Nominating Committee
of the Missouri Baptist Convention,
to ask each of the
Trustees of Southwest Baptist University
(from fall of 1977 to the present)
and each of the  SBU Administration
(from fall of 1977 to the present)
and each of the MBC Executive Board members
(from fall of 1977 to the present).

Please see:
the October 9, 2002
accompanying letter to the MBC officials.


Dr. Bob Curtis and other officials will receive their
written and signed copies of the
Thirty-One Questions for
President Dr. C. Pat Taylor
the SBU Trustees,
and the SBU Legal Staff
this week.

For more details and information, see:
Wounded Hearts:
"Questions of the Heart"Petition Website
 and
THE SOUTHWEST BAPTIST UNIVERSITY BOYCOTT
"MURDEROUS HEARTS:  
THIEVES, THUGS, AND LIARS FOR THE KINGDOM"

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 indoors 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 VANDALIZATION
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

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

Question 8 (22 parts a - v)
8. In your opinion, would participation or complicity
in any of the following actions (described in a - v)
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'
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 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 DEMAND by a SBU administrator that a student
act as an "informant" on her classmates and friends and
PROVIDE INFORMATION on the students' sexual
histories and activities.
Yes/No        

e) The abuse of ADMINISTRATIVE AUTHORITY to
engage in RETALIATORY SLANDER by the distribution
of FALSE accusations to a student's parents, friends,
employers, and other church members that a SBU student
was promiscuous and, therefore, UNWORTHY to pursue
a career in the ministry -- even though the student was
not even dating and unquestionably qualified as a virgin
by any definition.
Yes/No

f) The abuse of ADMINISTRATIVE AUTHORITY to
engage in RETALIATORY SLANDER 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 AFTER the student obtained MEDICAL PROOF
of her virginity.
Yes/No

g) The abuse of ADMINISTRATIVE AUTHORITY to
engage in RETALIATORY SLANDER by calling a
student's PARENTS to inform them that the student
was involved in prostitution and alcohol and drug abuse.
Yes/No

h) The use of ADMINISTRATIVE AUTHORITY to
encourage the sexual harassment of a SBU student by
other students -- 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

i) The abuse of ADMINISTRATIVE AUTHORITY
to engage in RETALIATORY SLANDER by 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" and "violent" and should not be permitted
to return home or to pursue a professional career
involving the ministry or working with children.
Yes/No

j) The ABUSE of ADMINISTRATIVE AUTHORITY
to deceptively gain access to a student's personal
belongings, personal papers, diaries, and study
notes in order to SEARCH and vandalize them as
a means of intimidating and DEBASING a student.
Yes/No

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

l) The use of ADMINISTRATIVE AUTHORITY to
engage in retaliatory slander by the circulation of FALSE
ACCUSATIONS to a student's parents and others that
a SBU student had worked as a prostitute and had
left campus to have an ABORTION and/or a CHILD.
Yes/No

m) The ABUSE of ADMINISTRATIVE AUTHORITY
to circulate FALSE accusations to friends, classmates,
and landlords and to REFUSE PERMISSION to other
SBU students to ROOM with a student in off-campus
housing on the grounds that other Christian students
should NOT ASSOCIATE with her because she was
promiscuous or was "NOT a suitable Christian student."
Yes/No

n) The use of ADMINISTRATIVE AUTHORITY to
engage in vindictive slander by the propagation of
FALSE accusations to a student's parents and others
that she should be required to have counseling for
what he termed "homosexual tendencies" because she
had DECLINED THE ADVANCES of a number of men.
Yes/No

o) The use of ADMINISTRATIVE AUTHORITY to
engage in vindictive slander by contacting a student's
friend (while the friend was student teaching) to
FALSELY ACCUSE the student of having become
DRUNK at a Springfield bar and becoming involved
in drunken brawl which resulted in a STABBING.
Yes/No

p) The ABUSE 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 proven to be FALSE
and INACCURATE -- in order to FURTHER discredit,
demean, and intimidate the student.
Yes/No

q) The ABUSE of ADMINISTRATIVE AUTHORITY
to engage in retaliatory slander and misinformation
for the purpose of DISRUPTING a student's CHURCH
and SPIRITUAL LIFE and preventing the student's
pursuit of a career in the Christian ministry.
Yes/No

r) The ABUSE of ADMINISTRATIVE AUTHORITY
by the deliberate retaliatory PSYCHOLOGICAL and
EMOTIONAL ABUSE of a distraught SBU student by
the recommendation that the student should commit
SUICIDE rather than attempt to explain her innocence
involving numerous FALSE ACCUSATIONS that the
SBU administration and others had made against the
student to her parents, friends, professors, employers,
and others.
Yes/No

s) The ABUSE of ADMINISTRATIVE AUTHORITY
to engage in retaliatory slander by propagating FALSE
ACCUSATIONS based on the MISINTERPRETATION
of the student's studies and STUDY NOTES by claiming
that the student was not actually engaged in research,
but was involved in the "OCCULT," Satanism, and
witchcraft, and should be denied church fellowship
and the opportunity to complete a degree program
at a Christian university.
Yes/No              

t) 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

u) The ABUSE of ADMINISTRATIVE AUTHORITY
to distribute FALSE ACCUSATIONS to a SBU instructors
and administrators, and subsequently to friends, that
a student was "promiscuous," "unstable" and "violent"
and, therefore, INELIGIBLE to pursue a CAREER
working with children.
Yes/No
       
v) The ABUSE of ADMINISTRATIVE AUTHORITY
to engage in the retaliatory PSYCHOLOGICAL and
EMOTIONAL ABUSE by the demand that a senior
student must submit to FORCED COUNSELING
for FALSELY-SUPPOSED childhood abuse in order
to complete a degree at SBU.
Yes/No

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

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 pesticide?
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
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 SBU?
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 SBU 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 criminally 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, SBU 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 SBU which, if discovered, would result
in criminal or civil penalties and political embarrassment?
Yes/No

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

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 SBU,
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 SBU student.
Yes/No

c) The DENIAL or OBSTRUCTION of COMMUNITY
and CHURCH ASSISTANCE to a 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 SBU employees, agents,
and associates.
Yes/No

i) The ABUSE of CHURCH LEADERSHIP
positions within the local church by SBU 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 SBU 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
SBU of 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, 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 Question 25.

Question 28
28. Did you participate in or are you aware of any
effort by PASTORS and CHURCH-RELATED
ORGANIZATIONS associated with SBU 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?"

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" SBU 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" SBU by making
civil and criminal complaints against them and,
therefore, "did not deserve" assistance?

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 SBU by making civil
and criminal complaints against them?
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 SBU or the
exposure of SBU students to dangerous pesticides and
solvents and 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