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The Lawsuit filed January 29, 2015 is reprinted and published here.

Michael W. Koper (CA Bar No. 281422)

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA – SOUTHERN DIVISION

MICHAEL KOPER, an individual and

BRITTANY KOPER, an individual,

Plaintiffs,

vs.

TRINITY CHRISTIAN CENTER OF SANTA ANTA, INC., a corporation,

INTERNATIONAL CHRISTIAN BROADCASTING, INC., a corporation,

MATTHEW CROUCH, an individual,

JANICE CROUCH, an individual, and

JOHN CASORIA, an individual,

Defendants.

Case No: ___________________

COMPLAINT FOR DAMAGES:

1. UNDER USCA 2520

2. UNDER CAL. PENAL CODE 637.2

3. UNDER CAL. CIV. COE 11708.8 AND DEMAND FOR JURY TRIAL

4. CIVIL CONSPIRACY

Plaintiff Michael Koper and Plaintiff Brittany Koper allege:

VENUE AND JURISDICTION

1. This Court’s jurisdiction over the subject matter is predicated on 28 U.S.C. 1332. The amount in controversy exceeds $75,000 exclusive of interest and costs.

2. This Court’s jurisdiction over the subject matter is also predicated on 28 U.S.C. 1331.

3. This Court’s jurisdiction over the subject matter is also predicated on 28 U.S.C. 1367.

4. Venue is proper in the Southern Division of the United States District Court for the Central District of California. All defendants reside in California, and at least one of the defendants resides in this judicial district and division. 28 U.S.C. 1391(a)(1).

Moreover, a substantial part of the events or omissions giving rise to the claim occurred in this judicial district and division. 28 U.S.C. 1391(a)(2). Moreover, there is no district in which the action may otherwise be brought, and at least one of the defendants is subject to personal jurisdiction in this particular judicial district and division at the time this action is commenced. 28 U.S.C. 1391(a)(3).

PARTIES

5. Plaintiff Brittany Koper is and has been a citizen of the State of New York. Prior thereto, Ms. Koper was a citizen of the State of California at all times mentioned herein.

6. Plaintiff Michael Koper is and has been a citizen of the State of New York. Prior thereto, Mr. Koper was a citizen of the State of California at all times mentioned herein.

7. Defendant Trinity Christian Center of Santa Ana, Inc., which also does business as Trinity Broadcasting Network (“Defendant Trinity Broadcasting”), is and was at all times mentioned herein a citizen of the State of California, and no other. Defendant Trinity Broadcasting is a corporation formed under the laws of the State of California and has its principal place of business in the State of California within the County of Orange.

8. Defendant International Christian Broadcasting, Inc., which also does business as Heroes Under God (“Christian Broadcasting”), is and was at all times mentioned herein a citizen of the State of California, and no other. Defendant Christian Broadcasting is a corporation formed under the laws of the State of Georgia and has it principal place of business in the State of California within the County of Orange.

9. Defendant Matthew W. Crouch is and was at all times mentioned herein a citizen of the State of California, and no other. Defendant Matthew Crouch is a resident of Orange County, California.

10. Defendant Janice W. Crouch is and was at all times mentioned herein a citizen of the State of California, and no other. Defendant Janice Crouch is a resident of Orange County, California.

11. Defendant John B. Casoria is and was at all times mentioned herein a citizen of the State of California, and no other. Defendant John Casoria is a resident of Orange County, California.

12. Unless otherwise alleged in this complaint, Plaintiffs are informed and believe, and on the basis of that information and belief allege, that at all times mentioned in this complaint, Defendants were the agents and employees of their codefendants, and in doing the things alleged in this complaint, were acting within the course and scope of that agency and employment.

RELATIONSHIP AMONG THE PARTIES

13. Defendant Trinity Broadcasting purports to be the world’s largest Christian broadcasting network. Defendant Christian Broadcasting is a nonprofit corporation that was formed by Defendant John Casoria and Paul F. Crouch, Sr. as a tax shelter for Paul F. Crouch, Sr.’s “personal money.”

14. Before she was terminated on or about September 30, 2011, Plaintiff Brittany Koper was Defendant Trinity Broadcasting’s chief financial officer (“CFO”), director of finance, corporate treasurer, and director of human resources. Plaintiff Brittany Koper was an officer and director of Christian Broadcasting, as well as the chief financial officer, director of finance, corporate treasurer, and director of human resources for numerous corporate entities affiliated with Defendant Trinity Broadcasting and controlled by the same board of directors.

15. Before he was terminated on or about September 30, 2011, Plaintiff Michael Koper was Defendant Trinity Broadcasting’s corporate secretary and vice president of media services. Plaintiff Michael Koper was also the corporate secretary for companies affiliated with Defendant Trinity Broadcasting and controlled by the same board of directors. Plaintiff Michael Koper was a director of Christian Broadcasting.

16. Plaintiff Michael Koper and Plaintiff Brittany Koper were husband and wife at all times mentioned in this Complaint. Plaintiff Brittany Koper’s maiden name is Brittany Crouch. She is the granddaughter of Paul Crouch Sr. and Defendant Janice Crouch, who were also husband and wife. Defendant Matthew Crouch is the son of Defendant Janice Crouch.

17. Paul Crouch Sr. is and was, at all time mentioned herein, Defendant Trinity Broadcasting’s founder, board member, president, and chief executive officer (“CEO”). Defendant Janice Crouch is and was, at all times mentioned herein, Defendant Trinity Broadcasting’s senior vice president and a board member. Defendant Matthew Crouch is Defendant Trinity Broadcasting’s vice president of programming and a board member.

18. Paul Crouch Sr., Defendant Janice Crouch, and Defendant Matthew Crouch maintained control over Defendant Trinity Broadcasting through exclusive and perpetual control of Defendant Trinity Broadcasting’s board of directors. Pursuant to Defendant Trinity Broadcasting’s articles and bylaws, Defendant Trinity Broadcasting’s board of directors is chosen solely by Defendant Trinity Broadcasting’s “members.” Circularly, though, Defendant Trinity Broadcasting’s “members” are defined as and limited to Defendant Trinity Broadcasting’s board of directors. The Crouches thereby elect themselves directors and maintain exclusive, perpetual control over Defendant Trinity Broadcasting’s affairs as the company’s only members/directors.

19. Defendant John Casoria is Defendant Trinity Broadcasting’s Assistant Secretary and General Counsel. He is also Defendant Janice Crouch’s nephew and is thereby Plaintiff Brittany Koper’s first cousin once removed. Plaintiffs are informed, believe, and based thereon allege that Defendant John Casoria is the director and senior manager of Redemption Strategies, and that this company was formed for the sole purpose of maliciously prosecuting, harassing, and intimidating Plaintiff Michael Koper and Plaintiff Brittany Koper (as well as members of Plaintiff Michael Koper’s family) in retaliation after the Kopers reported illegal conduct within Defendant Trinity Broadcasting, including unlawful distributions to Defendant Trinity Broadcasting’s members and directors on the order of $100 million.

GENERAL ALLEGATIONS

20. At the time she was terminated by Defendants on or about September 30, 2011, Plaintiff Brittany Koper had served as TBN’s Chief Financial Officer (CFO), Director of Finance, Corporate Treasurer, and Director of Human Resources.

21. At the time he was terminated by Defendants on or about September 30, 2011, Plaintiff Michael Koper was TBN’s Corporate Secretary and Vice President of Media Services.

22. Plaintiffs Michael Koper and Plaintiff Brittany Koper allege that Defendants wrongfully terminated Plaintiffs’ employment in violation of the public policies of the State of California and of the United States of America. Plaintiffs allege that such terminations were in retaliation for (a) Plaintiffs’ refusal to participate in conduct within Defendant Trinity Broadcasting made unlawful by the laws of California and the United States and (b) reporting such unlawful conduct to Defendant Trinity Broadcasting’s President, board of directors, to senior executive Defendant John Casoria, and to Defendant Trinity Broadcasting’s IRS auditor.

23. Plaintiff Brittany Koper was promoted by Defendant Trinity Broadcasting’s board of directors as the company’s Chief Financial Officer (CFO) and Director of Finance on or about July 5, 2011, and she was appointed as Defendant Trinity Broadcasting’s Corporate Treasurer on or about August 29, 2011. Following her promotion, Plaintiff Brittany Koper also continued to serve in her prior job function as Defendant Trinity Broadcasting’s Director of Human Resources.

24. In the weeks following Plaintiff Brittany Koper’s promotion, Defendant Trinity Broadcasting’s board of directors and senior executive Defendant John Casoria disclosed specific details concerning Defendant Trinity Broadcasting’s financial affairs to Plaintiff Brittany Koper. Plaintiff Brittany Koper was also given full access to company records.

25. During these weeks, Plaintiff Brittany Koper learned from Defendant Trinity Broadcasting’s board of directors and Defendant John Casoria that Plaintiff Brittany Koper had been chosen for the promotion to Defendant Trinity Broadcasting’s head of finance because the directors needed somebody “within the family” that they could trust to keep Defendant Trinity Broadcasting’s financial “skeletons” safely in the “closet.”

26. Plaintiff Brittany Koper learned through specific instructions from Defendant Trinity Broadcasting, Defendant Jan Crouch, Defendant Matthew Crouch, and Defendant John Casoria that the requirements of Plaintiff Brittany Koper’s new job included active participation in numerous illegal schemes that were disclosed to Plaintiff Brittany Koper following her promotion.

27. The nature of these illegal activities involved the systematic diversion of Defendant Trinity Broadcasting’s charitable assets through unlawful distributions to Defendant Trinity Broadcasting’s directors through numerous channels. The magnitude of these unlawful and related financial schemes uncovered by or disclosed to Plaintiff Brittany Koper is on the order of $100 million.

28. Plaintiff Brittany Koper and Plaintiff Michael Koper were terminated by Defendant Trinity Broadcasting because they refused to participate in the unlawful activities demanded by Defendant Trinity Broadcasting’s directors and senior executive Defendant John Casoria, and for making reports of those unlawful activities.

29. Plaintiff Michael Koper and Plaintiff Brittany Koper were specifically threatened and intimidated by Defendant Trinity Broadcasting’s directors and senior executive Defendant John Casoria when Plaintiff Michael Koper and Plaintiff Brittany Koper stated that these issues needed to be resolved and properly reported to state and federal officials. Plaintiff Michael Koper and Plaintiff Brittany Koper were told by Defendant Janice Crouch, Defendant Matthew Crouch, and Defendant John Casoria that they would have Plaintiff Michael Koper and Plaintiff Brittany Koper “arrested” and “prosecuted” if they tried to report Defendant Trinity Broadcasting or its directors for financial improprieties. Plaintiff Michael Koper and Plaintiff Brittany Koper were advised by Defendant John Casoria that they, too, had broken the same laws and that they were “prohibited” as “accomplices” from reporting alleged crimes outside the company. Plaintiff Michael Koper and Plaintiff Brittany Koper were told that they were required to go through Defendant Trinity Broadcasting’s attorneys, only, if they had concerns. And, Plaintiff Michael Koper and Plaintiff Brittany Koper were told that Defendant Trinity Broadcasting would have them arrested for “theft” if they took any documents to prosecutors. Defendant John Casoria also told the Plaintiff Michael Koper and Plaintiff Brittany Koper that they were bound by confidentiality agreements that prohibited them from reporting any illegal activities, and they were threatened with civil lawsuits.

30. On or about September 1, 2011, Paul Crouch, Sr. suffered congestive heart failure and was hospitalized. Defendant Janice Crouch and Defendant Matthew Crouch kept Paul Crouch, Sr. isolated from the rest of his family during this time and, in particular, Paul Crouch, Jr., Plaintiff Brittany Koper, and Plaintiff Michael Koper. It was during this isolation that Defendant Trinity Broadcasting’s board of directors announced that Plaintiff Michael Koper, Plaintiff Brittany Koper, and her father Paul Crouch, Jr. were all fired. When questioned about the termination, Defendant Matthew Crouch began tapping the firearm he had brought to the meeting and asked Plaintiff Brittany Koper what she thought would happen when she wrote a memo to the board critical of Defendant Matthew Crouch’s financial improprieties. Defendant Matthew Crouch continued tapping the gun he was holding to ensure that Plaintiff Brittany Koper recognized the lethal threat being made.

31. On January 29, 2014 Plaintiff Michael Koper and Plaintiff Brittany Koper discovered, for the first time, that multiple confidential communications they had with Paul Crouch, Sr., Defendant Matthew Crouch, and/or Defendant John Casoria were recorded by Defendants using an electronic recording device, and that these recordings had subsequently been edited and manipulated by Defendants. Defendants then disclosed and intentionally used these intercepted communications on multiple occasions.

FIRST CAUSE OF ACTION UNDER USCA 2520

32. Paragraphs 1-31 of this complaint are incorporated by reference as though fully set forth herein, and this claim under U.S.C.A. 2520 for violation of U.S.C.A. 2511 is asserted by Plaintiff Michael Koper and Plaintiff Brittany Koper against each of the Defendants.

33. Based on information and belief all the Defendants either intentionally intercepted, or procured each other to intercept, the oral communications of Plaintiff Michael Koper and Plaintiff Brittany Koper as described above.

34. Based on information and belief, the Defendants intercepted the communications of Plaintiff Michael Koper and Plaintiff Brittany Koper for the purpose of violating Cal. Penal Code’s 518, 519 and 523.

35. Based on information and belief, immediately following the interception of the communications of Plaintiff Michael Koper and Plaintiff Brittany Koper, Defendants sent, or caused to be sent, letters to Plaintiff Michael Koper, Plaintiff Brittany Koper, their family members, and other third-parties or organizations with whom Plaintiff Michael Koper and Plaintiff Brittany Koper had dealings. These letters threatened Plaintiff Michael Koper, Plaintiff Brittany Koper and their family members with arrest, accused them of committing crimes, and imputed crimes to them.

36. Based on information and belief, the Defendants sent these letters for the purpose of extorting and obtaining money and property from Plaintiff Michael Koper and Plaintiff Brittany Koper.

37. Based on information and belief, in addition to these letters, Defendants made, or caused to be made, multiple e-mail writings that threatened Plaintiff Michael Koper, Plaintiff Brittany Koper and their family members with arrest, accused them of committing crimes, and imputed crimes to them.

38. Based on information and belief, the Defendants sent these e-mail writings for the purpose of extorting and obtaining money and property from Plaintiff Michael Koper and Plaintiff Brittany Koper.

39. Based on information and belief, Defendants intercepted, disclosed and intentionally used the oral communications of Plaintiff Michael Koper and Plaintiff Brittany Koper on numerous occasions in violation U.S.C.A. 2511 and are entitled to bring a civil action under U.S.C.A. 2520.

SECOND CAUSE OF ACTION UNDER CAL. PENAL CODE 637.2

40. Paragraphs 1-39 of this complaint are incorporated by reference as though fully set forth herein, and this claim under Cal. Penal Code 637.2 for violation of Cal. Penal Code 632 is asserted by Plaintiff Michael Koper and Plaintiff Brittany Koper against each of the Defendants.

41. As set forth above, Plaintiff Michael Koper, Plaintiff Brittany Koper, Paul Crouch, Sr., Defendant Matthew Crouch, and/or Defendant John Casoria had several meetings and communications related to Defendant Trinity Broadcasting’s financial improprieties, which led to meetings related to Plaintiff Michael Koper’s and Plaintiff Brittany Koper’s terminations.

42. These meetings all took place only among these five corporate officers, one of whom is TBN’s general counsel, in the secure and locked President’s Conference Room of TBN located in Tustin, CA.

43. Based on information and belief, Defendants intentionally recorded these confidential communications using an electronic recording device without the consent of Plaintiff Michael Koper and Plaintiff Brittany Koper in violation of Cal. Penal Code 632 and are entitled to bring a civil action under Cal. Penal Code 637.2.

THIRD CAUSE OF ACTION UNDER CAL. CIV. CODE 11708.8

44. Paragraphs 1-43 of this complaint are incorporated by reference as though fully set forth herein, and this claim under Cal. Civ. Code 11708.8 is asserted by Plaintiff Michael Koper and Plaintiff Brittany Koper against each of the Defendants.

45. As detailed above, Plaintiff Michael Koper and Plaintiff Brittany Koper participated in meetings in the locked and secure President’s Conference Room regarding Defendant Trinity Broadcasting’s, Defendant Matthew Crouch’s, and Defendant Janice Crouch’s financial improprieties.

46. During these meetings Plaintiff Michael Koper and Plaintiff Brittany Koper were threatened with criminal prosecution, numerous civil lawsuits, and a loaded gun, all of which caused them to remain in the President’s Conference Room against their will.

47. Plaintiff Michael Koper and Plaintiff Brittany Koper knew the defendants had millions of dollars and several improper relationships with politicians and other government officials to back up their threats.

48. Plaintiff Michael Koper and Plaintiff Brittany Koper were fearful of these threats by Defendants and did not feel they could leave the President’s Conference Room. In addition, Defendant Matthew Crouch threatening Plaintiff Michael Koper and Plaintiff Brittany Koper with a loaded gun put them in fear that Defendant Matthew Crouch would physically harm them.

49. Based on information and belief, the actions of Defendants described above constitute both assault and false imprisonment, and all took place in the President’s Conference Room while Defendants were obtaining the sound recordings of Plaintiff Michael Koper and Plaintiff Brittany Koper’s oral communications.

50. Based on information and belief, Defendants committed assault and false imprisonment, or directed each other to commit such, with the intent to capture the sound recordings of Plaintiff Michael Koper and Plaintiff Brittany Koper, so they are entitled to bring a civil action under Cal. Civ. Code 11708.8.

FOURTH CAUSE OF ACTION FOR CIVIL CONSPIRACY

51. Paragraphs 1-50 of this complaint are incorporated by reference as though fully set forth herein, and this claim for civil conspiracy is asserted by Plaintiff Michael Koper and Plaintiff Brittany Koper against each of the Defendants.

52. Based on information and belief, each Defendant was aware that every other Defendant planned to intercept, disclose and intentionally use the confidential communications of Plaintiff Michael Koper and Plaintiff Brittany Koper.

53. Based on information and belief, each Defendant was aware that every other Defendant planned to use an electronic recording device to record the confidential communications of Plaintiff Michael Koper and Plaintiff Brittany Koper, without their consent.

54. Based on information and belief, each Defendant was aware that every other Defendant planned to commit assault and false imprisonment with the intent to capture the sound recordings of Plaintiff Michael Koper and Plaintiff Brittany Koper.

55. That each Defendant agreed with every other Defendant and intended that the above-described acts be committed.


PRAYER FOR RELIEF


WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:

(1) At least $75,000 in actual damages or more according to proof at trial;

(2) Statutory damages according to proof at trial;

(3) General and special damages according to proof at trial;

(4) Punitive damages;

(5) Reasonable attorney’s fees and other litigations costs;

(6) Interest according to law;

(7) Such other and further relief as this court may deem just and proper.

DATED: January 29, 2015 Michael W. Koper

By: _________________________________

Michael W. Koper

Attorney for Plaintiffs Michael Koper and Brittany Koper


DEMAND FOR JURY TRIAL

Plaintiffs hereby demand a jury trial as provided by Rule 38(a) of the Federal Rules of Civil Procedure.

DATED: January 29, 2015 Michael W. Koper

By: _________________________________

Michael W. Koper

Attorney for Plaintiffs Michael Koper and Brittany Koper

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