# Appendix — Worldwide Church of God, Inc. v. Superior Court of California > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385006_1778%3A04 ## Record - **Collection:** Supreme Court brief - **Document type:** Appendix - **Published:** January 1, 1980 - **Citation:** 446 U.S. 987 ## Text ® 4s ‘ ‘Vipreme Court, U. & ' FILED MAY 8 198° MICHAEL RODAK, JR., CLERM IN THE - Supreme Court of the United States = = October Term, 1979 No. 79-1348 WORLDWIDE CHURCH OF GOD, INC., ef al., Petitioners, vs. THE STATE OF CALIFORNIA, et al., Respondents. APPENDIX TO BRIEF IN OPPOSITION TO PETITION FOR CERTIORARI. GEORGE DEUKMEBIJIAN, Attorney General, LAWRENCE R. TAPPER, JAMES M. CorpDIi, WILLIAM S. ABBEY, LAUREN R. BRAINARD, Deputy Attorneys General, 3580 Wilshire Boulevard, Suite 800, Los Angeles, Calif. 90010, (213) 736-2044, Counsel for Respondent. Parker & Son, Inc., Law Printers, Los Angeles. Phone 724-6622 APPENDIX TO BRIEF IN OPPOSITION TO PETITION FOR CERTIORARI Page Appendix A. Pages 141-147, 150-171, Direct Examination of the Witness: Stanley R. Rader . . App. p. 1 Appendix B. Pertinent Text Matter by Court...... 22 Appendix C. Excerpts From Constitution and By- Laws of the Radio Church of God Preamble ..... 26 Appendix D. Declaration of Hillel Chodos ....... 35 Declaration of Hugh John Gibson .............. 37 Where Are We Now in the Panorama of Prophesied World Events? by Herbert W. Armstrong...... 42 Declaration of Benjamin Chapman ............. 50 Declaration of David R. Morgan............... 56 Declaration of Alvin E. Timmors .............. 58 Excerpts From Exhibit A to Declaration of Alvin Earl MES PRR as SMAO RT Oa Db ek Se a tne 64 Declaration of Shirley Timmons ............... 68 Appendix E. Employment and Consulting Agreement 70 Appendix F. From Transcript of March 12, 1979 NINE liao hs Pawibs viekka.d Oka we earns 86 Appendix G. From the September 21, 1979 Hearing, RE isis. vk wed een bs 4k eR ERS 88 Appendix H. Excerpt From Articles of Incorporation of Worldwide Church of God, Article II ........ 90 Excerpt From Certificate of Amendment of Articles of Incorporation of Worldwide Church of God.. 91 Appendix J. Excerpt From Order Dissolving Receiv- ership; Injunction, Pages 1 and 2 .............. 92 a il Page Appendix J. Declaration of Lauren R. Brainard in Support of Motion of Plaintiff to Hold Defendant's Discovery in Abeyance Until the Deposition of Stan- ley R. Rader Is Completed...........---+-++-- 93 Appendix K. From the January 10-12, 1979 Hearing Re: Appointment of Receiver: Pages 216-226, Direct Examination of Virginia N. Kineston .......-..-. 98 Testimony of John M. Kineston, Pages 229-241 .. 105 Direct Examination of John M. Kineston ......-. 106 Direct Examination of Chester Roberson ........ 110 Direct Examination of Paul Tulleners, Pages 262-266 117 Appendix L. Pertinent Testimony From Hearing of 1-11-79, Pages 366-367 ..........-- ee eee eee 121 APPENDIX A. Excerpts From Reporter’s Transcript, January 10-12, 1979 Hearing, Los Angeles Superior Court. pgs. 141-147 THE WITNESS: Stanley R. Rader, R-a-d-e-r. DIRECT EXAMINATION BY MR. CHODOS: Q. Mr. Rader, just to begin with, I noted a moment ago, from what Mr. Browne said and what you said, that members of the church prefer to affirm and not to swear: is that correct? A. That is correct. Q. Is there some religious tenet of the Church of God against swearing? A, ¥es. MR. BROWNE: Objection. I don’t believe— THE COURT: The objection is sustained. It is irrelevant. Q. BY MR. CHODOS: Mr. Rader, are you the man— May I approach the witness, Your Honor? THE COURT: All right. Q. BY MR. CHODOS: Are you the man who took this affidavit that was prepared for Mr. Armstrong’s signature to Tucson to have him sign it, the one that was filed in the court? A. No. Q. Did you see it before it was filed with the court? A. I’m not sure if I saw it before it was filed with the court, no. Q. It starts out and says: ‘*Herbert Armstrong being duly sworn upon his oath deposes and states.”’ And at the end it concludes, ‘‘subscribed and sworn to before me this Sth day of January, 1979,’’ and has the signature of a notary public. to | Mr. Rader, in your acquaintance with Mr. Armstrong, does he swear or does he affirm? MR. BROWNE: Objection, Your Honor. It’s irrelevant. THE COURT: Sustained. Q. BY MR. CHODOS: Mr. Rader, Mr. Browne men- tioned your employment contract. Do you have a copy with you? A. No. MR. BROWNE: I do. MR. CHODOS: Perhaps you could give one to the wit- ness. MR. BROWNE: Shall I give one to the witness, Your Honor? THE COURT: Yes, please. MR. BROWNE: For the record, I’m handing the witness the document on the stationery of Worldwide Church of God, dated August |, 1976, signed by Herbert Armstrong, followed by employment and consulting agreement, num- bering 18 pages, followed by employment and consulting agreement addendum, one page. MR. CHODOS: Can I have a copy to look at? MR. BROWNE: I haven’t collated them all. If you will wait a second. I have given a copy to counsel, Your Honor. THE COURT: All right. Q. BY MR. CHODOS: Mr. Rader, is that the employ- ment contract that as far as you are concerned is presently in force between you and the church? A. Yes. Q. The contract says— Your Honor, I would like to-mark that as Exhibit 3, I believe it is. pe, Sie THE CLERK: Plaintiffs’ 3, Your Honor. THE COURT: It is marked. MR. CHODOS: | and 2 were introduced at the earlier hearing, Your Honor. 1 was an authorization by Judge Weisman, and 2 was the original press release signed by Mr. Armstrong appointing Mr. Cole— THE COURT: All right. Q. BY MR. CHODOS: Do you have a pencil, Mr. Rader? A. A pen. Q. Just put a 3 in the lower right-hand corner of the first page in a circle. A. (Marking.) Q. Thank you, Mr. Rader. Mr. Rader, this document indicates that it was made and entered into on the 30th day of July, 1976 between you and the church; is that correct? That is what the contract says. Is that the truth? I'll stand on the written record. And— This is what it says. It’s signed by me and Mr. Armstrong. >O>rO> Q. Mr. Rader, my question was did you sign it on July 30, 1976? A. Ican’t remember that. I told you I'll stand on what the paper says. Q. Mr. Rader, who drew this contract? A. This contract was drawn probably by a young as- sociate in the firm of Ervin, Cohen and Jessup after dis- cussions with me. ihe Var I think his name is Greg somebody. | don’t know his last name. Q. Gittler? A. No. Q. And was Ervin, Cohen and Jessup representing you in that matter? A. No. Q. Who were they representing? A. I asked them to help to prepare these documents based upon instructions that had been given to me by Mr. Armstrong, and contracts with us prepared for Mr. Arm- strong for his son Garner Ted Armstrong and for me all at the same time. Q. In other words, there were three contracts prepared at the same time. Were they all prepared by Ervin, Cohen and Jessup? A. They were, to my knowledge, put into final form for Mr. Armstrong by the firm of Ervin, Cohen and Jessup, by a particular man named Greg somebody, whose last name I can’t recall. Q. And, Mr. Rader, you were the individual, were you not, who transmitted to Ervin, Cohen and Jessup’s firm the information as to what to put in these contracts for the three people? A. I told Ervin, Cohen and Jessup’s firm what provi- sions, in general, Mr. Armstrong wanted, what he was trying to accomplish by the employment contracts for each of the people. And I told them to put it into good form, and they did so. Q. Now, on page 2, Mr. Rader—sorry—page | of the agreement, in paragraph A, it recites that since March 1975, which is a year and three months earlier than the date of ee gt ~ . Amey ibaa Sanit ear bat cae en aime this agreement, it says ‘‘Rader has served as and is presently serving as a director, executive vice president, executive director, vice president for financial affairs, secretary-treas- urer and general counsel for the church and for its related entities.” Do you see that quote? A. Yes, very clearly. Q. And you were serving in all those capacities at the time this agreement was drawn up and signed, weren't you? A. Yes. But we would have to indicate which entity we are talking about and make specific which title I had in each one of the entities. Q. We will come to that in a minute. Now, Mr. Rader, you were the general counsel for the church. Was that you, yourself, or was that your firm of Rader, Helge and Gerson? A. The firm of Rader, Helge and Gerson is merely an association of three lawyers, and Mr. Helge is the person who deals primarily with the church and its related affairs as these problems come up. pgs. 150-171 Q. Mr. Rader, who advised the church about the ad- visibility or the propriety or desirability of this contract? A. Mr. Herbert Armstrong is God’s apostle. He is Christ's representative here on earth at this time. He, by the powers that have evolved upon him spiritually and which, as | understand, after constant review with my co-counsel, Mr. Helge, he has the power to hire and fire, set rates of compensation, things of that nature, and has done so con- sistently for 46 years. Q. Mr. Rader, he is not a lawyer, is he, Mr. Armstrong? A. No, sir, he is not a lawyer. cali sa Q. Did he have any other lawyers advising him besides you and Mr. Helge about this matter? A. Mr. Herbert Armstrong calls upon lawyers when and ift— THE COURT: Mr. Rader, I think it will help us all if you will listen to the question. You are a lawyer. Respond only to the question. All right? THE WITNESS: All right. THE COURT: All right. THE WITNESS: Can you repeat the question, please. MR. CHODOS: I'll repeat it. Q. Did he have any other lawyer besides you and Mr. Helge advising him about entering into this contract from the church when he did so? A. Not to my immediate first-hand knowledge. Q. Mr. Rader, there have been other transactions be- tween you and the church in the past few years, the purchase of your home and so on; is that correct? A. In which years? Q. Let’s take your home on Loma Vista, Mr. Rader. The home on Loma Vista was originally purchased by the church with church money; is that correct? MR. BROWNE: Objection, Your Honor. Let me tell you why I’m objecting here. It’s too remote. I’ll offer to show that the home was purchased in 1971, and we are prepared to go into that transaction—it occurred eight years ago—to show how the home was purchased, how Mr. Rader assumed the obli- gations, the fact the money of the sale of the previous home went into it. The occyrrence in 1971 does not have the immediacy for this hearing. I think this Court wants to know what has Ae happened in the last 90 days, what has happened in the last 60 days. THE COURT: Mr. Browne, we can’t separate it to that extent. I think some background is going to be necessary. And I am going to have to rely on the good judgment of counsel, both of you, not to enlarge this to the full trial on the merits. Some background is going to be necessary. MR. BROWNE: | think eight years ago is— THE COURT: It is a big asset he is talking about, and I think he is entitled to go into that, but only cursorily. MR. CHODOS: If | can have 20 minutes I'll be through with this part. THE COURT: Another comment I want to make, gentle- men, and that is going to help us move this along, and that is if you are going to make an objection, you make your objection in legal form and stop. If I require any argument, I will let you know. Q. BY MR. CHODOS: Mr. Rader, the question was, in 1971 the church bought the house at 840 Loma Vista: is that correct? A. That is not precisely correct. Q. Originally the title was put into your name; is that correct? A. Title was in my name upon— Q. You have answered the question. A. Yes. MR. BROWNE: Your Honor, objection. Can the witness give an answer, and if it requires an explanation let him do it without counsel saying, **You have answered the ques- tion’’? We are on a fact-finding mission. THE COURT: All right. Mr. Chodos, give him a chance to explain if fie so desires. wee de Q. BY MR. CHODOS: When the property was origi- nally acquired, was the title put in your name? A. When the property was originally acquired the prop- erty was put in my name. And that was under the specific direction and authorization of Mr. Herbert W. Armstrong who actually selected the home. Q. All right. Now a few months after— The money for buying the property came from the church funds, didn’t it? A. The money for the purchase of the property, as | recall, was borrowed on a short-term basis from the United California Bank for the purpose of buying the house for cash. Q. It was borrowed by the church and then paid to buy the house? A. That’s correct. Q. Now, Mr. Rader, a few months after the house was originally bought, you quitclaimed the property to the church, didn’t you? A. That’s correct. Q. Then/about a couple of years later the property was transferred by the church into your name again; is that right? A. No. Approximately one year later, when the per- manent financing was arranged, I quitclaimed the property to the church so that the financing would be available once it became impossible for me, as an individual, to acquire it all by myself. After the financing had been arranged for, as my affidavit indicated, the property was then transferred to me, I believe, January 1972, or approximately thereof, and | then assumed some mortgages, gave back a second mortgage, and trans- ferred other property to the church. Wisi Ra ta Ro Mm ST _ an Q. Mr. Rader, at the time that all this was happening, your firm was peoviding legal counsel to the church, and your other accounting firm was providing accounting serv- ices to the church; is that right? A. In 197— Q. °71 and ’72. A. °71 and '72 | was representing the church as a law- yer. Q. Did Mr. Armstrong or the church have any inde- pendent counsel at the time of those transactions? A. Not to my actual knowledge, but it is quite possible that they did. MR. CHODOS: Move to strike the part about it is quite possible that they did. THE COURT: Speculation, and it will go out. Q. BY MR. CHODOS: Now, Mr. Rader, when you— in 1974, October of 1974, the property was conveyed by the church to you and Mrs. Rader, was it not, in exchange for your assuming a $218,000 liability on the existing loan and giving back a second of $145,000? A. Ido not believe that 1974 is correct, Mr. Chodos. I said the property was conveyed on or about January 1972. Q. Allright. In any event, Mr. Rader, since the property was occupied by you in the first instance, it is true, is it not, that the church has paid all the payments for the mort- gage, the maintenance, the furnishing having to do with that property? A. Not true, Mr. Chodos. Q. The church has paid the charges, haven't they” A. In some years. Q. And not in others? niin. A. That is correct. Q. How did it come to pass that they paid in some years and not in others? A. To—that will involve a theological explanation, which I would be happy to go through, Your Honor. It would take quite some time, and we would have to call Mr. Helge— ; Mr. Helge to give the theological explanation? And the legal aspect of it. Are you a minister of this church? No. You have been baptized into it in 1975? That is correct. O>O>N>O . Mr. Rader, do you know how much money the church put into this property? THE COURT: The house? MR. CHODOS: The house. MR. BROWNE: Objection. I don’t understand. You mean at the original time of purchase? Q. BY MR. CHODOS: No. Up until now, up until you sold it. A. It was my understanding, Mr. Chodos, that any pay- ment made to me or for my benefit will be reflected on the books and records of the institution. THE COURT: If you don’t know the answer, state you don’t know. THE WITNESS: I—well—I don’t. Q. BY MR. CHODOS: It is somewhere around $800,000, isn’t it, Mr. Rader? A. I wouldn’t think so. Q. $500,000? ee MR. BROWNE: Objection, Your Honor. | think the ques- tion is asked and answered. THE COURT: If the witness knows, he can so state. THE WITNESS: I don’t know. Q. BY MR. CHODOS: Mr. Rader, in any event, you and Mrs. Rader sold this property in the summer of last year; did you not? A. That's correct. Q. And the sales price was $1,800,000? A. That’s correct. Q. And you have kept that money, that didn’t go to the church; isn’t that right? A. That is correct. Q. Now, at any time, Mr. Rader, was there any inde- pendent advice to Mr. Armstrong or to the church con- cerning your ownership or sale of the house on Loma Vista that you know of? A. Ican’t answer, because I don’t know. Q. All right. Now, in addition, Mr. Rader, the house has—the church has bought you a house in Tucson; is that correct? A. lam using a home in Tucson that was purchased by the church; title is in my name. Q. How much did that house cost the church, Mr. Rader? A. Approximately $150,000. Q. The church paid for furnishing it, correct? A. It was bought furnished and a few items were added. Q. Mr. Rader, in addition to the house in Tucson, you and Mrs. Rader also own a house in Pasadena? A. That’s correct. ee, we Q. That is the house you bought from the church is that correct? A. That is correct. Q. You paid the church about $255,000 for that house a few months ago, correct? A. That is correct. Q. And the way you did that was you paid $75,000 cash, and gave the church back a deed of trust for about $150,000; is that right? A. Initially, but 60 days later the one fifty-two was paid off. Q. Now, Mr. Rader, does the church—has the church paid for the cars that you drive? A. Iam entitled to— THE COURT: Listen to the question, Mr. Rader. Just listen to the question. ; THE WITNESS: Well, I don’t know. I would have to check my employment contract. Q. BY MR. CHODOS: Do you have an Aston Martin and Porshe? A. Those are mine. Q. Did the church pay for those? A. No. Q. Mr. Rader, I would like to go back to something that you mentioned a little while ago on the matter of your different roles that you play. You have been, as I understand it, Mr. Rader, you and your lawfirm, Rader, Helge and Gerson, have been counsel for the church for many years; is that correct? A. The association of Rader and Cornwall and—excuse me. Rader and Helge and Gerson have represented the church and its related entities for a good many years, yes. « 3 eal rere Ae a anita Roe tie "008 chp ALD eS i ha PR PII Or tt Ca LE: i eg. os leek car Bathe ils eS ba soil, ies THE COURT: Mr. Rader— THE WITNESS: It is an association; it is not a partner- ship. It is very important. THE COURT: I think you will save us all some time and expedite this if the question is susceptible to a yes or no, just answer yes or no. You need not repeat the whole ques- tion. All right? THE WITNESS: Yes. Q. BY MR. CHODOS: Mr. Rader, in addition to that, you have been a member and founding member of the ac- counting firm of what is now known as Rader, Cornwall, Kessler and Palazzo; is that correct? A. Fee Q. As I understand it, Mr. Rader, in addition to that, you organized an advertising agency called Worldwide Ad- vertising, Inc., which acted as the advertising agency for all the church’s media purchases, time purchases? A. ¥es. Q. And in addition to that, Mr. Rader, you organized an entity known as Mid-Atlantic Leasing, or something like that, which purchased airplanes and leased them to the church; is that correct? A. Yes. Q. And let me ask you, Mr. Rader, in connection with any of these activities or services or supply of assistance to the church that you provided through these various en- tities, did the church have any independent counsel besides yourself or your firm? MR. BROWNE: Objection, Your Honor. Irrelevant to the scope of these proceedings. THE COURT: Overruled. You may answer the question. a” te THE WITNESS: My I ask Your Honor something? He is using the word independent. Does he mean independent of me or in addition to me? He is not being precise. THE COURT: I assume he means by independent coun- sel, counsel other than your firm, which had no connection with your firm, is that correct? MR. CHODOS: Yes. THE WITNESS: Remember I have asked Your Honor to understand the difference. My firm is not a partnership. THE COURT: Be that as it may, let’s talk about the three people who were associated together. Bearing in mind that is the context of the question, | think, what is your response? MR. BROWNE: Objection, Your Honor. Can we have the time frame about this leasing company? THE COURT: I don’t think that is necessary, Counsel. MR. BROWNE: I think it’s 1967, Your Honor. THE COURT: I don’t think it matters. MR. BROWNE: Ten or eleven years ago? THE COURT: I indicated to you, Mr. Browne, I think some background is going to be necessary. The quicker we get to it, the quicker we will dispose of the issue now. MR. BROWNE: May I inquire, Your Honor? My problem is this. These transactions are brought up. Was Mr. Armstrong independently represented. Now with- out regard to that answer, I feel compelled to now dem- onstrate to Your Honor by way of rebuttal they were all fair transactions, that they were proper financially, because | know Mr. Chodos is going to argue just because of the so- called specter of undue influence that we have a problem. And I know that if he gets into those underlying transactions, a) we are going to be here a long time. And I feel it’s somewhat of an unfair disadvaritage in that respect. THE COURT: I want to assure both of you we are not going to be here for a long time, as I already indicated to you. Mr. Chodos, you are going to have to move this along. I think you are getting into detail that is not going to assist the Court very much in particular with this ruling. MR. CHODOS: I asked to have 20 minutes. If I don’t spend it all on objections, I will be past it. THE WITNESS: May I help, Your Honor, in one way? THE COURT: Yes sir. THE WITNESS: I don’t know whether Mr. Armstrong has consulted independent counsel. That is because Mr. Armstrong is inclined to consult independently of everybody with other people, and I never know with whom he’s speak- ing at any one time. THE COURT: Your answer is you don’t know. THE WITNESS: Yes. Q. BY MR. CHODOS: Mr. Rader, a few things about these financial matters. It’s my understanding somewhere in the—let me ask you a foundation question. We have in our moving papers, which you have read— You have read them, haven’t you? A. Not completely. Q. We have attached copies of a document—I think it’s called the Pastor’s Report, which is sort of a mimeographed or offset printed publication of the church. A. Yes. Q. And in those reports there are messages from you; correct? ee That’s correct. You are in fact the author of those? 2 2? That’s correct. Q. If something appears in the Pastor's Report over your name, that is your statement? A. That's correct. Q. Somewhere in those papers—I’ll find it, if you need it—you say you severed all your connection with Worldwide Advertising; is that right? A. In 1975, that’s correct. Q. Is that when you became a full-time officer of the church? And a member of the church. You don’t have anything to do with it now? Nothing. It’s now all owned by Mr. Gerson? Worldwide advertising? ¥es. Is owned by Mr. Cornwall. Mr. Gerson, what does he have to do with it? Nothing. . He’s on the door there as counsel for Worldwide Advertising. Do you know anything about that? OFOFOPOPOP A. Yes. He subleases space from Mr. Cornwall. Q. Mr. Cornwall is the gentleman of Rader, Cornwall, Kessler and Palazzo? He’s the Cornwall in that group? A. By name, yes. | Q. Now I understand also, Mr. Rader, that sometime a while ago Worldwide Advertising was no longer—stopped handling the advertising agency function for the church? A. That’s correct. BD RES se eiee A hes I cena er « CS re eS S? SBS oe Otel aS a Q. The church agreed to pay them something like $375,000 for termination damages; is that right? A. I don’t know the details. I was not privy to the transaction. I don’t know. Q. You don’t know anything about it? A. Iknow something about it, but I never participated in the transaction. Q. Mr. Rader, can you tell me, did you know that the executive payroll checkbook of the Worldwide Church of God was out at Worldwide Advertising, Inc.? Yes. The executive payroll records? Yes. And they were out there a week or so ago? Yes. What were they doing there, Mr. Rader? The executive payroll had been prepared for some time under the direction of Mr. Cornwall. And Mr. Cornwall at that time was acting as a certified public accountant. OP eS Ce? And Mr. Armstrong’s instructions were that the executive payroll should be prepared in that manner. When Mr. Corn- wall, as I understand it, retired from the public accounting field, he assigned the duties of preparing that—those payroll checks—which is a clerical function—to someone who had formerly been working under his direct supervision. Q. Is Mr. Cornwall now an officer of the church? A. No. Never was. Q. Does he have any—is he employed by the church? A. No. Q. He has no connection with the church organization or college or foundation at all? a A. As I understand it, there is a contract between Mr. Cornwall and the church which nad to do with this termi- nation, and he may have rights under the contract for pay- ment as some kind of consultant. Q. Does he prepare the executive payroll now? A. No. | just stated the executive payroll has been prepared for some time by another man who formerly was Mr. Corn- wall’s employee when he was practicing as a public ac- countant. Q. This employee is a— A. You have to ask that of someone else. Q. Now, Mr. Rader, on the matter of the leasing com- pany—then we will be off of this by a quarter of 1 1:00— some years ago, you and others formed a firm of some kind, an entity, to buy an airplane and lease it to the church; is that right? A. That’s correct. Q. And since that time, you and others have bought more than one plane and leased it to the church? A. That is correct. Q. And in fact, there is a plane the church is using now called a Grumman II, that was bought by you and leased to the church; is that correct? A. Yes. Q. All right. The church—the terms of the lease were such, were they not, Mr. Rader, in every instance, that if the lease had been fully paid, the lease payments would cover the full purchase cost and an interest factor or service charge factor, in addition, for the lessor; is that right? A. They were leases, and whatever the lease provisions would provide— ees a a ee eS ee — = THE COURT: If you don’t know, say you don’t know. THE WITNESS: I don’t know. Q. BY MR. CHODOS: They were at least finance, purchase-type contracts, weren’t they? In other words, the party paying the lease was, in effect, bearing the entire cost of the time purchase; isn’t that right? A. They were leases. They were leases. You would have to examine the documents if you want to say something else about them. Q. Mr. Rader, do you not know whether the terms of the lease were such that the church’s payments were in- tended to cover the full purchase price, plus a profit to the lessor for providing the financing; isn’t that true? It depends on which plane we are talking about. Well, let’s talk about the Falcon. Which Falcon? How many Falcons were there? There were two. Let’s talk about the first one. Let’s talk about the second one, the most recent Falcon. Isn’t it true that the purchase payments were intended to cover the full purchase, the lease payments were sufficient to cover the full price plus? A. On the second Falcon there were serious limitations on the amount that the lease would give in terms of the difference between the pay out of the lease and the amounts that the lessee would pay. In other words, no one knew until the end whether such a figure would be paid. THE COURT: You know what the plane cost, don’t you”? THE WITNESS: Yes. THE COURT: What did it cost? O>rO>rao> axe, Wan THE WITNESS: Well, the plane upon the trade-in was about $2.3 million. THE COURT: What were the lease payments totaled over the period of the lease? THE WITNESS: They were to be a certain amount per month, but the interest rate was variable and could not exceed a certain amount to the purchaser. THE COURT: What were the parameters of that? THE WITNESS: Well— THE COURT: The lowest and the highest in the form of the lease payments. THE WITNESS: Well, I don’t have the contract in front of me. I can’t— THE COURT: What is the equivalent, basically the pur- chase price of the plane? THE WITNESS: Just about; just about. Q. BY MR. CHODOS: Now, Mr. Rader, in fact, some- time in 1977, the chruch decided to terminate the Falcon lease; is that right? A. Yes, in 1977. Q. And under the provisions of the lease, who drew up that lease, your firm? A. No. Q. Ervin, Cohen and Jessup? A. No. Q. Who drew it up? A. The lease was drawn by lawyers in the east, I un- derstand. Q. Penalty of $620,000 for early termination was paid in 1977, for the termination of that Falcon lease, isn’t that right, to the lessor? Sate silent ee a. we A. I’m not sure that that was the amount. I don’t know whether it was a penalty, per se. Q. I will get to that. A. The lease was terminated, and it is a matter of re- cord. Q. I will get that to you in just a minute, Mr. Rader. But while I am at it, the church then bought the Grumman II? No. They have the Grumman II? They bought the Grumman II in 1970. Q. Now the church has made all the lease payments on the Grumman II, completed making all the lease payments last year sometime or before; isn’t that right? A. Yes. Q. Has the title to the Grumman II ever been transferred to the church? A. ¥@6. Q. When did that happen? A. I think sometime in 1978. Q. How long after,the payments were made? ees A. Within the period of time necessary for all the clos- ing documents to be gathered. Mr. Helge, I think, handled that. woe. Yael APPENDIX B. Excerpt From Reporter’s Transcript, January 12, 1979 Hearing in Los Angeles Superior Court. Pages, 387- 391. (THE COURT:) There may be other reasons, but certainly on the basis of market value, there really has been no showing. Never- theless, there have some very serious questions raised here concerning the use and transfer of assets in the form of money and property to those in control of the church. Again, the weight of the evidence and the final conclu- sions in regard thereto will have to be determined by the trial court. But I have heard enough, | think, during the course of these hearings, and from my examination of the documents, to at least give me some cause for concern and to lead me to the conclusion that pending the trial some restraints must be imposed on the operations of the church until the action, as I say, is finally determined. Now, what have some of these questions amounted to? Well, firstly, there has been an astonishing amount of money expended here by Messrs. Armstrong, Rader and others for many purposes, particularly in connection with so-called travel expense, the purchase of extensive gifts and so forth. Now, certainly, some expenditures along that line are completely proper and permissible, and they are certainly within the discretion of those persons who are authorized to determine whether they should be made. Of course, the persons have to be authorized, it seems to me—They have to be authorized to indicate and decide what amounts of money should be expended. And the au- thority of those persons allegedly authorizing them have to be persons, as I say, who are in proper authority in. the church. kinds. These are questions which are open to, | think, some arguments, and will have to be examined very carefully at the time of trial. Now, it can generally—with reference to the conduct of the affairs of the church, the administration of its assets and the expenditures over the last several years, and up to the present time—it seems to be conceded that in spite of the fact that the articles are filed in this corporation under the nonprofit clause of the State of California, and in spite of the fact there are specific provisions in the articles and bylaws which place control in the board of directors, it seems, nevertheless, to be conceded that for many years this was essentially a one-man operation, with Mr. Arm- strong making all the decisions on a completely unilateral basis; and perhaps even more recently it has been a two- man operation, in the sense that both he and Mr. Rader are acting jointly. And of course, as you all know, there is some suggestion—at least there is an inference, because of Mr. Armstrong’s possible inability to continue with his activi- ties, either because of advancing age or infirmity or disa- bility of one kind or another—that perhaps it is now basically a one-man operation, again with Mr. Rader conducting the affairs of the church. All of these issues will have to be very carefully scruti- nized by the trial court, and they all represent reasons why the court is concluding here that some restraints have to be placed on the conduct of the church business from this point forward, or at least until trial. MR. CHODOS: Could you speak a little more in the microphone, Your Honor? THE COURT: I wiil do the best I can. 1 am gradually running out of steam. There have some serious inferences which have been also raised concerning various transactions between Mr. Rader er ee and the church, from claims of self-interest, possible con- flicts in interest; again all of those being problems which are going to have to be resolved in the trial court. But there has been enough in the way of questions raised which, again, place the court on notice that there might conceivably be some problems on the part of Mr. Rader with reference to the church. Some of these relate to his possible involvement in, for example, leasing aircraft to the church and having an interest in the leasing company; var- ious other business dealings with the church. I am not going into those now in detail, but they all, again, will have to be examined by the trial court. Now, again, I am not going to dwell on it. There has been the problem raised about these homes which have been transferred to Mr. Rader, one of which he subsequently and concededly sold at a profit of perhaps one million dollars or thereabouts, which he has retained as his own property. There are also questions with reference to the legal effect of his employment contract under which he receives a salary of some $200,000 a year, plus substantial expenses, with no apparent approval of anyone except perhaps Mr. Arm- strong. That is certainly an issue which is open to serious examination. Mr. Rader is an attorney, of course. I question—I don’t know right now the answer—but I certainly question the legality of his present employment argeement, the enforce- ability of that present employment agreement with the church under these circumstances. The defendants have taken the position, I think, coinci- dentally so, that Herbert Armstrong is and is entitled to be in sole control of the church, since it is what the defendants have referred to as a hierarchy; as I say, in spirit of the law, the articles, the bylaws, the fact this is a nonprofit corpo- ration and the fact that the articles and bylaws—certainly the bylaws provide that the control is vested in the board of directors and not in Mr. Armstrong. Mr. Armstrong apparently has taken the position that he may do what he pleases with reference to the affairs of this church, and without consulting with anyone else, including the board of directors. When you combine this with the inference that Mr. Rader {may] now in reality have replaced him or is in the process of replacing him it becomes obvious, it seems to me, that the trial court will have to make a full inquiry into this situation. ai.. APPENDIX C. Excerpts From Constitution and By-Laws of the Radio Church of God. CONSTITUTION ARTICLE | NAME This association, a corporation, shall be known as RADIO CHURCH OF GOD. ARTICLE II OBJECT The object and purpose of this Association shall be to carry out the active ministry, according to the call and commission of Jesus Christ, of the tue CHURCH OF GOD and its various local Churches of God with which it is associated and from which it has come into being, which scriptural call and commission is: |) to preach and to publish the true Gospel of Jesus Christ, which is the New Testament MESSAGE which God sent by and was preached by Jesus Christ our Lord—the Gospel of the Kingdom of God, in all the world as a witness unto all nations in fulfillment of the prophecy for this time of Matthew 24:14; 2) to effectively warn the people of the United States, the British Common-wealth of Nations, and the Democracies of Northwestern Europe whom we understand to be the descendants of the House of Israel, of the divine judgments from Almight God prophesied soon to fall on our peoples in punishment unless we repent of and turn from our in- P POE Oe eat FOE HOR Ee Fe ‘ CTS rr re —er ae creasing sins and violations of God’s laws, and return to national and individual total reliance upon the God of our fathers; 3) to be used of God in the conversion of souls; 4) to minister to those whom God adds to His Church, feeding the flock with the pure Word of God by personal contact and by literature; 5) to establish, raise up, and maintain according to the New Testament pattern, local churches composed of those whom God gives us; 6) to establish and conduct one or more educational in- stitutions or other instruments to educate and train students for active duty in this ministry of worldwide evangelism, organization and conduct of local churches; 7) to minister to the material need of God’s people, by healing of the sick through prayer and faith in God’s prom- ises of healing, and whatever other physical or material ministry we may be equipped to give. ARTICLE III MEMBERSHIP Section 1. Those who are recognized members of all local churches affiliated with this Association, together with those active co-workers in this ministry, whether by tithes and - offerings and prayers only, or by this and personal active full or part-time service, who have been baptized into Jesus Christ and show evidence by the fruits of their lives of having received and being now led by the Holy Spirit of God and who keep the Commandments of God and the faith of Jesus Christ, and who acknowledge this as their sole and only church affiliation shall be considered as members of the RADIO CHURCH OF GOD. Section 2. Reception of Members: No person can *‘join’’ the Radio Church of God or any of its affiliated local Churches of God, in the usual sense of the word. We con- ceive, as revealed in Holy Scripture, that God adds to the Church such as are being saved, and it is by His Spirit being received on Conversion that one is baptized or inducted into the true Body of Christ. Any person qualifying according to Section | first above, in whom we perceive the grace of God as manifested by the ‘‘fruits’’ borne in his or her life, shall, if located near or visiting one of the local churches, be given the right hand of fellowship in public meeting by the local membership; or, where not accessable to a local congregation in our fellowship, such members, consideered as already having been added to the Body of Christ, the true Church of God, by the Holy Spirit, shall be if when possible extended the right hand of fellowship by any authorized minister or representative of this Body. Isolated members, however, may be considered and recognized as members of the RADIO CHURCH OF GOD without, or pending being extended the right hand of fellowship in this personal manner. “Article III, Section 3. Dismissal of Members: We are warned in the New Testament that even of our own selves shall men arise, speaking perverse things to cause division and draw away disciples after them: and that ‘wolves’ in ‘sheep’s clothing,’ making an ap- pearance and pretense of being true disciples or min- isters, will enter in among God’s true Christians for greedy purpose. We are commanded, and the authority therefore vested in the Church, if the same be deemed expedient for the protection or other benefit of the Church, to mark them that cause divisions and offenses contrary to the teaching of the Bible, to make a full Statement of the reasons to the congregation for doing so, and/or disfellowship such persons and avoid them. The determination as to which remedial procedure is ee, a to be invoked, and whether or not the same is ‘deemed expedient,’ shall be within the sole and subjective dis- cretion of the ministers duly authorized by the Church to make such a determination.’”’ ARTICLE IV DIRECTORS, OFFICERS, AND DUTIES THEREOF Section 1. Board of Directors: The corporation shall be controlled by a Board of Directors, which shall consist of thirteen in number, who shall also be Trustees. All Direc- tors, except Herbert W. Armstrong, shall be appointed for a term of one year or until such time as a successor is appointed. Herbert W. Armstrong shall hold office perpetually by virtue of having been called by divine authority of Jesus Christ as evidenced by the founding, development and growth of this work, the salvation of souls, the raising up of local churches of those converted by and through this ministry, the effective proclaiming of the true Gospel to the entire nation by word of mouth, by radio, and by printed word, which achievements could only be accomplished by the divine direction and the power of God working effec- tually in and through the one specially called for this mis- sion. Section 2. Executive Officers and and Duties: A) The President of the corporation, who shall be a mem- ber of the Board of Directors, who also is Pastor of this Church. He shall be the Chairman of the Board of Directors. He shall, by virtue of his office by devine calling and di- rection, have power and authority to appoint all other Di- rectors and administrative officers, after counsel with the other directors and prayer. B) A Vice President, whose duties shall be to act as president in the absence of the president. — = C) Secretary-Treasurer, who shall keep all minutes of Board meetings and Church meetings, and records of the organization, and shall account for and be responsible for all monies received. Section 3. Duties of the Pastor: \t shall be the duties of the Pastor to preach over the radio, and, when feasable, by television; to write booklets and literature; to edit the PLAIN TRUTH magazine; to preach before public audiences; to preach when possible before our local congregations; to pray for the sick; to ordain elders and deacons; to teach or su- pervise the teaching of the Bible and courses of Religion at the College training prospective ministers and workers for the mission to which we have been called: to have general Oversight and supervision of the Church and its work. Section 4. Administrative Officers: The President of the corporation shall be the Executive Director over the active administration of the work of evangelism; and in the conduct of the business affairs of this active evangelistic ministry, there shall be employed, responsible to him, such admin- istrative, executive, secretarial and other help as the conduct of the purposes of this Association may require, including, as at present organized: (1) A Business Manager, whose duties are to manage and supervise all routine and ordinary business administration, including employment and direction of secretaries, file clerks and other office employees; the purchase of supplies; the payment of accounts, supervision Over auditing and keeping of books and records and reports, and other ad- ministrative departments. The Business Manager shall be directly responsible to, and under direction of and in close cooperation with the President, with whose knowledge and consent all important or out-of-the-ordinary decisions or policies shall be made. =e (2) An Office Manager, under direction of the Business Manager, who shall supervise the routine of the general office, maintaining and checking the mailing list and ad- dressing machine system, mimeographing, mailing of re- quested literature, booklets, the PLAIN TRUTH magazine, etc. ; (3) An Auditor, in supervision of auditing and book- keeping department, who shall audit all financial records of The RADIO CHURCH OF GOD and its auxiliary or- ganizations or institutions at least once each year, and report to the President, the Secretary-Treasurer, and the Board of of Directors, their true financial condition. He shall have access to all records of monies received and of expenditures and amounts, payable at all times. He shall act also as adviser and counsellor in the financial affairs of the Church. (4) An Executive Secretary, serving as personal secretary to the President. (5) A Financial Secretary, who shall be manager of the mail opening department, and, in supervision over trusted, trained and qualified secretaries, shall be responsible for the opening of mail, receiving of all monies, and turning of these monies promptly over to the executive secretary or auditor or whomsoever the Business Manager shall direct for entering in records and banking. It shall be the further duty of the Financial Secretary’s office to carefully read all incoming mail, channelling each piece into the proper de- partment or office for attention and reply; marking carefully what special literature is requested or, in judgment of sec- retary, would be helpful. (6) Manager of Printing Department, in supervision over printing of booklets, bulletins; letters, letterheads, envelopes and other literature. (7) Manager Recording Department, who shall be in charge of radio studio control room and whose duties are to make all recordings of radio programs by electrical tran- scription for broadcast, packaging and alr-expressing same to various radio stations; keeping careful records of all tran- scribed programs sent to each station; and maintenance con- tinually in best condition of all radio and recording equip- ment. (8) Superintendent of Buildings and Grounds, who shall be directly responsible Business Manager who in turn is responsible to the President of the College for maintenance and repair of buildings, new construction supervision, su- pervision over all janitor work; also for supervision and maintenance of all grounds, lawns, trees, shrubs, hedge, etc., and any new installation thereof or landscaping. No new building construction or landscape installation may be contracted for, however, or undertaken, unless ordered by Business Manager with consent of the President of the Col- lege and approval of the Board of Directors. ARTICLE XII INDEMNIFICATION OF OFFICERS AND DIRECTORS Every person who serves as a director, officer, or em- ployee of the corporation, and every person who serves at the written request of the corporation (or at its oral request subsequently confirmed in writing) as a director, officer, or employee of another business, whether or not incorpo- rated, in which the corporation owns a proprietary interest, may, in the discretion of the Board of Directors, be indem- nified and held harmless by the corporation from and against any loss, cost, liability, or expense that may be imposed on or incurred by him in connection with or resulting from any claim, action, suit, or proceeding, civil or criminal, in which he may become a party or otherwise involved because of his being or having been a director, officer, or employee of the corporation, or of the other business in which the corporation may own.a proprietary interest, whether or not he has this relationship when the loss, cost, liability, or expense was imposed or incurred. The phrase ‘‘loss, cost, liability, or expense’’ shall include all expenses incurred in defense of the claim, action, suit, or proceeding and the amounts of judgments, fines, or penalties levied or rendered against the indemnified person, provided that no person shall be entitled to indemnity under this section unless the Board of Directors determines that he was acting in good faith and within what he reasonably believed to be the scope of his employment or authority and for a purpose that he reasonably believed to be in the corporation’s best interest. The determination of the Board of Directors shall be within its sole and subjective discretion and its decision shall be final. Payments authorized under this section shall include amounts paid and expenses incurred in settling the claim, action, suit, or proceeding, whether actually begun or only threatened. Expenses incurred with respect to a claim, ac- tion, suit, or proceeding indemnified against under this sec- tion may be advanced by the corporation before final dis- position of the matter. This right of indemnification shall not affect any other rights to which any person may oth- erwise be entitled by law or contract. ea 6 & 2 This CONSTITUTION has been recommended by the Pas- tor, and approved by the majority of the members present at this annual meeting, this 24th day of October, 1948. (Signed) HERBERT W. ARMSTRONG Pastor and President of corporation (Signed) LOMA D. ARMSTRONG Vice-president pes.” ae (Signed) ESTHER OLSON Secretary-treasurer (Signed) BASIL WOLVERTON Elder and Director (Signed) D.T. HENION Deacon and Director (Signed) JAMES A. GOTT Deacon and Director 35... APPENDIX D. Excerpts From Declarations and Exhibits in Support of Ex Parte Application for Temporary Receiver, Filed January 2, 1979 in Los Angeles Superior Court. DECLARATION OF HILLEL CHODOS I, HILLEL CHODOS, hereby declare as follows: 1. Iam one of the attorneys for the relators in the within action. I make this declaration in support of the ex parte application for appointment of a temporary receiver, tem- porary restraining order, and order to show cause. I have personally discussed this matter with the Hon. Steven S. Weisman, a retired judge of this court, in order to ascertain whether he would be willing and able to act as receiver if appointed by this Court. Judge Weisman has told me that he is willing and able to do so. 2. I have practiced law for approximately seventeen years. I specialize in business and corporate litigation and in trial in appellate courts. Much of my practice relates to cases of business and commercial fraud involving large amounts of money and large corporate enterprises. 3. I have personally interviewed all of the declarants whose declarations are filed in support of the within appli- cation. I have also reviewed the materials they have fur- nished to me. These materials strongly suggest that the Church may have substantial claims against the individual defendants and other persons for improper diversion and misappropriation of church funds. They also suggest strongly that the Church has ample legal grounds for avoiding the consummation of a proposed sale of its major asset in Big Sandy, Texas. However, based on my experience in liti- gation, it is my opinion that the ascertainment and pursuit of those claims will be greatly facilitated if the records of the Church are fully preserved and available to the counsel pa WS charged with doing so; and that their ascertainment and prosecution will be rendered much more difficult if any substantial segment of the records has been destroyed. It is therefore of the utmost importance to the ultimate en- forcement and protection of the charitable trust that whatever records remain in existence be preserved from removal or destruction. 4. Itnow appears that a proposed sale of the Big Sandy facility will close on January 4, unless orders are made which will prevent the closing. Based on my experience in business litigation, including many real estate matters, it is my opinion that the legal difficulty and expense involved in setting asid2 a consummated sale would be much greater than that involved in avoiding the consummation of the transaction before it is complete. I declare under penalty of perjury that the foregoing is true and correct. Executed this 28th day of December in Beverly Hills, California. /s/ Hillel Chodos HILLEL CHODOS eS: DECLARATION OF HUGH JOHN GIBSON I, HUGH JOHN GIBSON, declare as follows: 1. JI am one of the attorneys for plaintiff and relators in the within action. I make this declaration in support of the plaintiffs’ application for appointment of a receiver and a temporary restraining order, and for a receiver and an injunction pendente lite. 2. During approximately the last two weeks, I have been furnished by certain of the relators with various written material and information pertaining to the Worldwide Church of God, Inc. and its associated corporations. I have reviewed and analysed those materials, and have pursued certain additional inquiries and investigations. The follow- ing facts appear (among numerous other facts) in said ma- terials and are pertinent to this proceeding; and may be briefly summarized for the Court’s convenience as follows. 3. Attached hereto, marked Exhibit A, is a copy of the ‘*Pastor’s Report’’ published by the Worldwide Church of God on August 14, 1978. At pages 4-7, the report contains a personal message from Stanley Rader. In it he explains he is employed by the Church under an arrangement made between him and Herbert W. Armstrong that “*whatever it took to meet my financial requirements would be provided.”’ He acknowledges that he arranged for the lease-financing of a Falcon aircraft for use by Church executives; that ‘‘after careful consideration and much discussion with all parties, it was agreed that the financial arrangements were equitable for all parties and that my participation would not be in conflict with the Church or any professional responsibilities that I might have had as a result of my relationship to the Work as a lawyer and as an advisor to Mr. Armstrong;”’ and that the arrangement provides for the Church to indem- nify him from any tax loss he might suffer in connection aaa with it, which indemnification was in the process of being calculated as of the date of the report. Mr. Rader also admits that for many years he was the owner of an advertising agency which handled all of the Church’s radio and tele- vision time buying activities on a commission basis [Mr. Rader claims in the report that he divested himself of any and all interest in the advertising agency in 1975; but as appears more fully below that claim is highly questionable]. Mr. Rader also admits that the Church purchased and main- tained a home for him in Beverly Hills [recently sold by him personally for $1,800,000, as explained more fully below]. Mr. Rader claims that all of this remuneration was approved by Herbert W. Armstrong, who allegedly felt and feels that he has been ‘‘a servant worthy of his hire.’’ 4. The current edition of Martindale-Hubbell lists Mr. Rader and his law firm, Rader, Helge and Gerson. In ad- dition to the official listing, the directory contains a paid listing for the law firm, setting forth biographical infor- mation concerning its members and other information. A copy of this paid listing is attached hereto marked Exhibit B. It lists Mr. Rader as a lawyer and also indicates that he is a certified public accountant. Among the representative clients of the law firm are included Ambassador College, Worldwide Church of God, Ambassador International Cul- tural Foundation, and Worldwide Advertising, Inc. World- wide Advertising is the advertising firm Mr. Rader formed to handle the Church’s time buying programs, and in which he allegedly divested himself of any interest in 1975. 5. Areview of current telephone directories reveals that Mr. Rader maintains law offices at 10100 Santa Monica Boulevard, telephone number (213) 552-1717. Worldwide Advertising, Inc. is listed in the telephone directory at the same address and phone number. Also listed at the same address and phone number are Henry F. Cornwall, C.P.A. eS, Ue and Gateway Publishing, Inc. The accounting firm of Rader, Cornwall and Kessler, and W. Jack Kessler, C.P.A., are listed with offices at 10100 Santa Monica Boulevard and a telephone number of 553-6958. 6. Attached hereto marked Exhibit C, is a Dun & Brad- street report on the Worldwide Church of God, Inc., dated July 18, 1978. This report lists Herbert W. Armstrong as president; Stanley R. Rader as treasurer; and Ralph Helge (Rader’s law partner) as secretary; and states that the three officers are the directors. It also states that Armstrong, Rader and Helge hold identical offices in Ambassador College, Inc. 7. Attached hereto, marked Exhibit D, is a Dun & Brad- street report dated September 28, 1978 on Ambassador In- ternational Cultural Foundation, Inc. Messrs. Armstrong, Rader and Helge are listed as the president, executive vice president and secretary; and Henry Cornwall (Rader’s other accounting partner) is treasurer. 8. I have examined the ‘‘Pastor General Department, Report of Expenditures’’ for July 1, 1975 through June 30, 1976, which is attached to the Declaration of Mr. Chapman as Exhibit B. This report lists a total of $2,031,643 ex- penditures by the Church during this period, consisting prin- cipally of items characterised as ‘‘travel and lodging’’ [$889,485] and ‘‘public relations’’ [$819,346]. The item- ized breakdown shows repeated expenditure for luxury items such as meals at Perino’s or La Scala, limousine service, and the like. Typical of these items are bills incurred by Rader at Perino’s on February 28, 1976 ($272.34) and at La Scala on March 12, March 18 and March 19 ($125.00; $202.71 and $102.18 respectively). Other items which ap- pear repeatedly throughout the itemized list are charges at Hermes in Paris (a luxury store with a branch on Rodeo Drive), Gucci (a similar establishment), Christian Dior, eae” en Cartier, and so on. Another category of items which fre- quently appears relates to charges to the Church, as exec- utive expenditures by Osamu Gotoh for cameras and ac- cessories: by way of example only, between June and September of 1975, he is listed as having purchased over a dozen cameras and related equipment from various pho- tography stores for over $10,000. 9. In addition to ongoing and enormous expenditures of this character, the report also lists travel expenditures of bizarre and exorbitant amounts. Typical items are: 8/8/75 American Express-Gotoh Hotel Plaza Athenee, Paris (no backup) $12,416.93 8/31/75 American Express-Gotoh Imperial Hotel, Tokyo (no backup) $13,735.74 9/12/75 American Express-Gotoh Munich, Germany $12,504.59 9/11/75 Diners Club-Rader Hotel Plaza Athenee, Paris $12,049.39 Between October 23 and November 1, 1975, Gotoh made four charges to the Church’s American Express card at the Plaza Athenee totaling over $44,000; and a week later, he billed another $8,580.29 to the Church for a Stay at the Imperial Hotel in Tokyo. On February 25, 1976, Rader made nine separate charges to the Church’s Diners Club card at the Jerusalem Hilton, amounting to more than $10,000. I have also examined the monthly executive expense anal- ysis of March 3, 1978, attached to the Declaration of Mr. Timmons as Exhibit C. This report reveals that the type of expenditure shown in the 1975-1976 report is continuing to more recent times. The analysis includes a bill by Rader at the Plaza Athenee in Paris for $22,571.19: a bill for Henry Cornwall at the Imperial Hotel in Tokyo for $22,- ee en 925.56; and charges at La Scala ($694.78), Harrod’s ($281.98) and the like. 3 The report for March 3, 1978 also reveals additional major expenditures of significance. During the period reflected by that report, the Church incurred $13,166.90 for Rader’s home in Beverly Hills, including utilities, property tax, landscaping, expense allowance and mortgage payment. During the same month, the Church incurred an additional $10,591.17 to furnish and maintain Rader’s home in Tucson. 10. Despite the fact that the Church paid for the Beverly Hills home, including taxes and maintenance, Rader and his wife held personal title to the property until they sold it in July of 1978 to Erwin and Margo Winkler. A certified copy of the Raders’ grant deed to the Winklers is attached hereto marked Exhibit E. The documentary transfer tax is listed as $1,980, computed on the full value of the property conveyed, signifying (at $.55 per $500) a sale price of $1,800,000. 11. Shortly after selling the Beverly Hills home and pock- eting the money, Rader and his wife purchased a home in Pasadena from Ambassador College for an apparent pur- chase price (based on transfer tax) of $225,000. The Church took back a note and trust deed for $152,500 of the purchase price. Certified copies of the grant deed and the deed of trust given back are attached hereto, collectively marked Exhibit F. | I declare under penalty of perjury that the foregoing is true and correct. Executed this 27th day of December, 1978, at Beverly Hills, California. /s/ Hugh John Gibson HUGH JOHN GIBSON am Excerpts From Exhibit A to Declaration of Hugh John Gibson: Pastor’s Report. Where Are We Now In the Panorama of Prophesied World Events? by Herbert W. Armstrong The DEATH of Pope Paul VI may trigger a drastic change in world events. This change could plunge the world into the most terrifying crisis ever experienced by man. But I hasten to add that if this catastrophic World War III does explode, that will be the definite ASSURANCE that WORLD PEACE in the utopian WORLD TOMOR- ROW— is imminently to follow. I would rather picture to our readers a future of WORLD HOPE, than of horrifying world disaster. But we live in a troubled world with unprecedented evils piled mountain- high. And the trend is foreboding—not reassuring. It will get darker before the DAWN. The important thing is that the DAWN is absolutely assured by the living Creator GOD! Some twenty years ago, before Pope John XXIII was elected, I had wondered if the Pope then being selected by the College of Cardinals would be the one who would pro- pose his good offices to the nations of Europe to achieve political, monetary, and military union. European nations have longed for some sort of UNITY. They want not only economic union, as they have achieved by the ‘“Common Market,”’ they fear the communist hordes—and especially if the U.S.S.R. and the Peoples Republic of CHINA ever get together. United now—since World War II—the Europeans have had to rely on the United States military power to protect them from further encroachments or nuclear attack from the Soviet Union. Back during the final days of World War II, I was giving a commentary on the war news daily on the World To- or oe morrow radio program. We came to a point where the final coup de grace was expected hourly to be rendered on Ger- many by the Allies. But the Western Allies could not inflict that final death-blow until the Russians ended their part of the war in the eastern sector. Day after day, hour after hour, we waited. But the Rus- sians were in no hurry to END the war. They continued on, until they had taken over Latvia, Estonia and Lithuania— and until the Russian boot had been firmly planted on all Eastern Europe—including Eastern Germany. All these be- came the ‘‘satellite countries.’’ They are spoken of as behind the ‘‘Iron Curtain.’’ All who know communist beliefs, aims and tactics, know that they are committed to waging this war, by propaganda, by infiltration and fifth-column tactics, by sabotage and guerilla warfare—and, when necessary, finally by open all- out nuclear war. The Soviet Union maintains a very huge standing army. The Soviet Union competes on a virtual parity with the J.S.A., as the world’s two superpowers in military strength. And the Europeans are right on their border. They know how communism did prove the ‘‘domino theory’’ correct in Viet Nam. They not only continued on from North Viet Nam to conquer South Viet Nam—even with full U.S.A. participation with its military force—but then quickly Cam- bodia and Laos fell. And, next in the ‘‘domino falldown’’ is to come Thailand, Burma, Malasia. Singapore a few years ago successfully stopped a threatened communist take- over—but now they are in the “‘domino’’ orbit. The Europeans are far more disturbed about their safety in relying on United States military power to protect them than Americans realize! The United States is not loved in Europe. European confidence in U.S. protection against their next-door communist neighbor has been lessening and lessening. ee ae EUROPEANS WANT THEIR OWN UNITED MILI- TARY POWER! They know that a political union of Europe would produce a THIRD MAJOR WORLD POWER, as strong as either the U.S. or the U.S.S.R.—possibly stronger! They have made a real effort toward union, in the Com- mon Market. It has made them economically strong. United they could become stronger economically than the United States. The dollar continues dropping in European and Jap- anese markets—and especially the German MARK has soared stronger and stronger! But they well know there is but ONE POSSIBILITY of union of Europe—and that is through the Vatican. Two leaders in Europe produced, a few years ago, two different plans for union. The former Archduke Otto von Hapsburg of Austria, and the ‘‘strong man of Europe,’’ Dr. Franz-Josef Strauss of Munich. I know the latter well. He has been a dinner guest in my home. Five years ago I felt, personally, that the more likely plan that might come to fruition was that of the former Archduke of Hapsburg, but the most likely man to HEAD such a union was Franz-Josef Strauss. However, we all become a year older every year, and there has been so much delay that a younger man may now head up such a European union. As I said before, when Pope John XXIII was in process of election, I felt that the Pope elected might be the one who would make available his good offices to help political leaders of Europe bring about their hoped for union. But | at once it became eviden: that Pope John had other ideas. He started the Ecumenical Movement, to bring about a different kind of union—a Church union between Protes- tants, Eastern Orthodox Catholics, and the Roman Catho- lics. Then fifteen years ago, I thought Pope Paul might be the one to lead in this European political union. But the res- ay urrection of the old ‘‘Holy Roman Empire’’ was again de- layed. Pope Paul continued with Pope John’s ecumenical union project. But that was not to be accomplished. * * * * * PERSONAL FROM STANLEY R. RADER There has been a systematic effort to destroy the reputations of Mr. Herbert W. Armstrong and those closet to him. This effort was spear-headed by Garner Ted Armstrong, but aided and abetted by those seeking favor with him. Mr. Armstrong has written and spoken about this during the past few months, and I am certain that you will recall similar efforts on his part to correct the problem during the past several years. Although my record of performance is well known and well documented, there has nonetheless been a conspiracy to place a cloud over it, and to impune my character, my reputation and my professional integrity. My financial ar- rangements with the Church, matters which are of record and known to all parties with the right to know them, have been falsely distorted and made to appear wrongful. Ac- cordingly, I am taking this opportunity to share the record with you in order to put to rest once and for all the spec- ulations and misapprehensions in this area. When I first met Mr. Armstrong the Work was very small— the total gross revenues from all sources was less than $800,000 annually. Mr. Armstrong soon learned that he could rely on me to get problems solved—problems that were not being solved by others for whatever reasons. He asked me to represent the Work on a retainer basis. We agreed that the Work would prosper, and in time I would be compensated in accordance with the scriptural principle that ‘‘a servant is worthy of his hire.’’ | had great faith in the Work and in Mr. Armstrong and I threw myself into = my responsibilities with the zeal and energy necessary to get the job done—with little regard to my compensation. By 1969, I had helped Mr. Armstrong in many ways and we had come to love one another very much. We had a very special relationship which I shall always cherish as will my wife and my children. I was still very successful on two other fronts—in my law practice and in my public account- ing practice. At that time, however, Mr. Armstrong and Mr. Portune asked me to come into the Work ‘‘a little more’’ by giving up all other professional activities that required my Own commitment of time and energy. We agreed and, from that time forward, I devoted all my time, talent and energy to Mr. Armstrong and the Work. We agreed that whatever it took to meet my financial require- ments would be provided. Prior to 1969 the only financial dealings that I had with the Work were for the payment of my professional services, with one exception. At Mr. Armstrong’s specific request in 1967, I managed to arrange for the financing of the first Falcon aircraft after all other attempts to do so by Mr. Portune and his colleagues in the business office had been unsuccessful. The only way that I was able to provide the financing for the completion of the purchase of the falcon from Pan American Airways was to arrange a tripartite agreement between Mid-Atlantic Leasing, Pan American Airways and the Church. Mid-Atlantic Leasing was a part- nership which was formed for the transaction. The part- nership was willing to act as the lessor if it would be guar- anteed certain tax shelter benefits. Furthermore, since it was impossible for a partnership to be assured of the Church’s credit- worthiness, the partnership required that 1) I take part in the transaction and that 2) I indemnify each of the other partners in the event of the Church’s default in any material respect. ae. ee After careful consideration and much discussion with all parties, it was agreed that the financial arrangements were equitable for all parties and that mv participation would not be in conflict with the Church or any professional respon- sibilities that I might have had as a result of my relationship to the Work as a lawyer and as an advisor to Mr. Armstrong. At that time, it was also clearly foreseeable that at the termination of the lease the provisions of the tax law would result in a definite tax loss for me. The Church agreed to indemnify me from such loss if, in fact, it were to occur. In July 1977, the lease was terminated, but well in advance of the termination date provided for in the lease agreement. Accordingly, I am now in the process of calculating the actual economic loss that I have suffered as a result of the transaction that began in 1967. In the fall of 1969, Mr. Armstrong decided to terminate the services of his advertising agency, M. B. Scott, Inc., and he determined that it would be in the best interest of the Work that the time-buying function be transferred to an agency that would be more under the control of the Work. Mr. Armstrong and Mr. Portune were both aware of my vast background and experience in the advertising field as a result of my contact over the years with Mr. Scott and other advertising agencies, as well as my broad overview of the entire communications field as a result of my law practice. Hence I was asked to form an Advertising Agency and to limit its activities to representation of the work. From the late fall of 1969 until March 1975 when I was baptized, I was the president of Worldwide Advertising Inc., although several years prior to that time I had delegated away most of the day-by-day operation. During the years 1969 through 1975, copies of the Worldwide Advertising income tax returns were made available to Mr. Portune and my remunneration to Worldwide Advertising was, of a course, included as an important item on those tax returns. In 1975, upon my baptism, and of course after becoming a diretor and an officer of the church and the college, it was necessary for me to divest myself of any and all interest in Worldwide Advertising. Prior to 1971, I never lived in a faculty or college home. Although Mr. Armstrong, and others thought it would be better for me to live in the Pasadena area, my wife was unwilling to make the move from Beverly Hills and hence we did not. In 1971, however, it became clear to Mr. Arm- strong, to Mr. Portune and to me that there would be benefits of a substantial nature io the Work if I were to be able to undertake the responsibility of seeing to the needs of the very important overseas visitors that were coming to Cali- fornia at Mr. Armstrong’s invitation, and also to maintain a residence that would lend itself to the type of formal and large scale receptions also necessary to fulfill the various responsibilities of the Work as a result of its ever-increasing activities throughout the World. Accordingly, a more appropriate home was found in Beverly that was, in Mr. Armstrong’s opinion, the perfect residence for such activities. We did not feel, however, that it would be possible for me to live in such a residence on a tax-free basis as did our ministers and faculty members. Hence, we agreed that I would purchase the home. Financing would be arranged with the help of the Church and my remuner- ation would be adequate to cover the increased costs. For many, many years Mr. Armstrong has stated on more than one occasion that I am the highest-paid individual in the Church. This fact is well known to responsible persons at Headquarters. Whether I should be the most highly-paid person in the Work, of course, is something for Mr. Arm- strong, as Christ’s apostle, to decide. I do not feel, however, ~ te a —-— mw. te oe gs 9 wose! (SOO OPN) Jorg PEeenN Wer” fymoag ‘DONTE (9F6t | “arf) PRMOHNIED JO Assay ‘meq JO 282105 “EY6I ‘sdt05 aurresy *S'A “adeQ) -enniosye5 jo seg SBUNStH ‘wonesnpas (e831 ! 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AT IayII0N Is9CM Ie Su; sus3ag . r Riles ot Tet E SBAOTTOS 88 paeqyirseep ‘jzoe12y3 UOTII0d 3PY2 ICT Pree Ory ONT LIIDKT > ? , *AIuNOD pyes 30 Lapaozey AUN) ay3 JO a24330 P 5 742 UT ‘sdey jo 9 a8eq ‘9g yoog Uy papi0odsea dew sad ee “4992 °ON 32BAL JO OF 207 PIUIO;TLT) JO 21815 * STTIONV SOT jo dyuney : ff : ’ “STTIN ATW3A39 4O ALTO ey ut Avsadosd yeas paquszeap Furso)/0) ay) { j ron *Aqaadord Aqyurwmo>d 13042 se ‘azyA pus PURQENY “YFINNIA OOMYN GNV WZIXNTA NIANI 7 ’ t. ISTINVHD 4q240q Brits % + ha ira ee 4, eRe “2378 pue purqeny ‘YaqVa ZITVLYN GAY waave ‘x ATWVLS : 4 >> ms etna ‘padpojmouwpe Aqasay m qorys jo Ida “NOLLVHICISNOD TIAVIIVA ¥ MOS | ; ‘ ee MOMRDUEOMCETE rs FO MED ms ease pesmi um, ; | att pO aust ie Suruiewe: someiquin we pus SEO] JO antes eee onien ying uoO Ordme> | y JO “PONIeUOD stadurd fo onyen tiMy Uo De wor | xy i ~- : “J0'Age'T 8 YW) sapere sy sa IUIN Og ’ 1 FY | 8) 2u9p wp (S:s0mrwia po --eionun aE i isiani Rs i) | H Bi Swedes Date ee cw eh. eo eee sere ” | Peaq jUeID jenpiaipyy : e i, . a‘. % s qe ‘- A ———— 389 6 BI0NODIw Od INIT BIML BACEY B>vES ‘ , rr] 14, ’ j ks si. — 2 o.23 } i WORY NAAIS ose stv ae ’ e- we Beeps ite Se — 0 - ' ei ead 3 ae — . = pe { oe Sem @emeeiee = «4 wee wea’ Ta that | should be embarrassed that Mr. Armstrong has felt that | have been a servant worthy of his hire.”’ | have had no other financiai dealings with the Work and | have never been involved as a recipient directly or indi- rectly of any favor, financial or otherwise, from any person or institution that has had dealings with the Work. My reputation in the community is without blemish and | intend to keep it that way. With Christian love, Stan Rader $0... - DECLARATION OF BENJAMIN CHAPMAN 1. My name is Benjamin Chapman, and my business address is Department of Theology, Ambassador College, 300 West Green Street, Pasadena, California. | am above the age of eighteen years and, if called as a witness, I could testify to the following out of my own knowledge. 2. 1am making this Declaration with the understanding that it will not be used in any way for the personal financial gain of myself, or of any other individual, but for the col- lective good of all the members of the Worldwide Church of God, and with the hope that greater fiscal responsibility will be achieved in the Worldwide Church of God. 3. I hold a Bachelor of Science degree from UCLA in Engineering, which I earned in 1957: I also hold a Bachelor of Arts degree from Ambassador College, and a Master’s degree in Theology from that same institution. I am pres- ently employed full time as an Instructor in Theology at Ambassador College and as a Pastor in the Worldwide Church of God. 4. Richard David Armstrong, the eldest son of Herbert W. Armstrong, died in the 1950s. I married his former wife in 1961 and we have been married ever since. Because of this, I have been almost a member of Mr. Armstrong’s family for many years. 5. Iam presently, and I have been since 1963, a Pastor of the Worldwide Church of God. In 1963, the Church sent me and my family to Texas, where I pastored congregations in Dallas and Fort Worth. In 1964, I also became a faculty member, administrator and minister at the Big Sandy cam- pus of Ambassador College, in Texas, and I occupied that position until 1973, when I was called to Pasadena to be- come the Manager of the Data-Processing Department and, later, Director of Circulation for the Church. inal actie 6. To my recollection, it was in the early part of 1974 that Mr. Herbert W. Armstrong appointed me to sit on the Board of Directors of the Worldwide Church of God, Inc., and I occupied a position on that Board for a number of months. At that time, a Ms. David John Hill was a teacher at Ambassador College and was also a member of the Board of Directors of Ambassador College, Inc. It was brought to the attention of Mr. Armstrong that a conflict of interest might exist because of Mr. Hill's dual role as an employee and director of the College, so I was asked by Mr. Arm- strong to swap Board positions with Mr. Hill, and in that way I became a member of the College Board. | served in that capacity until the Spring of 1975, when I was asked by Mr. Armstrong to resign my position on the College Board. 7. To my knowledge, all members of the boards of directors of the Worldwide Church of God, Inc., Ambas- sador College, Inc., and Ambassador International Cultural Foundation, Inc., are and always have been appointed by or under the direction of Mr. Herbert W. Armstrong. Mr. Armstrong also personally approves ordination of all Church Pastors. In recent years, he has accepted recommendations from others regarding ordination. 8. During 1974 and 1975, I was employed full time as Director of Circulation for the Worldwide Church of God, Inc. My duties in that position included supervision of all the data-processing functions of the Church, and so I became familiar with a number of the reporting procedures in use in the Church at that time, especially those concerning media and literature requests and responses. 9. Ihave been employed full time by either the World- wide Church of God, Inc., or Ambassador .College, Inc., for over eighteen years. Because of my long and continuous association with the Church, I am familiar with Church aS, a doctrine and practices, and with the evolution of those doctrines and practices over the last fifteen years. 10. The Church maintains a computerized data-base of all persons who either receive its literature, participate in its ecclesiastical functions, or contribute money to it. This data base supports a subscriber development system, which is one of the means by which the Work of the Church is accomplished. 11. To my knowledge, no member of the Church, re- gardless of the amount of frequency of his financial con- tributions to the Church, has ever, at any time, been asked to vote, or ever has actually voted, upon any matter con- cerning the governance of the Church: even upon matters which are not ecclesiastical, such as the selection of directors or the expenditure of Church funds. And despite the fact that I served on the Board of Directors of both the Church itself and the College, I myself never had an opportunity to express my personal opinion on any Church matter by means of a vote. Instead, I and the other board members were simply asked to approve decisions made by Herbert W. Armstrong or in his name. I am acquainted with mem- bers of the boards of various corporations affiliated with the Church and, to my knowledge, the role I played as a Board member of the Church and then of the College is typical of the role played by the other members of the boards involved. 12. To my knowledge, all Church funds are received from charitable contributions made to the Church. Very little of these funds is earned from income from Church investments. This has always been true and, as far as I know, continues to be true to the present day. 13. All these charitable contributions are made to the Worldwide Church of God for the purpose of furthering its religious mission, which is referred to in the Church as ‘‘the Work’’. Contributions from all over the United States are received by and deposited to the bank accounts of World- wide Church of God, Inc., Ambassador College, Inc., and Ambassador International Cultural Foundation, Inc., all in Pasadena, and all disbursements of those funds are made by those same corporations. 14. Financial reports of Church receipts and disburse- ments are disseminated to members of the Church from time to time, but these reports are never detailed more than a simple balance sheet and income statement, and the mem- bers of the Church do not generally have access to the records which would substantiate them. Part of the financial reporting has been done orally: Mr. Armstrong and Mr. Stanley Rader read portions of the reports to the congre- gations assembled to observe the Feast of Tabernacles. Some of the reporting is done in written form: a copy of one such recent report, which appeared in two separate issues of The Good News, is attached here as Exhibit *‘A’’. 15. recognize the Pastor General Expense Report at- tached here as Exhibit ‘‘B’’ to be in the form customarily given to such documents in the Church. Judging from its form and content, and based on my personal knowledge of the character and magnitude of the expenditures in these categories at that time, I believe it to be what it purports _ to be: a copy of a report actually made within the Church; and I believe it reflects with substantial accuracy the actual expenditures borne by the Church during the time period it purports to cover. Although I am no longer a member of the Board of the Church, nor Director of Circulation, | believe that the expenditures reflected in the attached Exhibit ‘*B’’ are continuing today. 16. Other reports, which were computer-generated, were regularly made and delivered to select individuals in ee Ae tana ee ee ee se Mills: the Church at all times while I was Director of Circulation for the Church. I believe that those same reports, or other reports substantially similar to them, are still generated and circulated within the Church today. 17. Ihave known Mr. Stanley R. Rader for nearly eight- een years. | met him when we were both involved in the Work in Bricket Wood, England, in 1960. 18. Mr. Rader is presently a lawyer, and a C.P.A., and has advised and counseled Mr. Herbert W. Armstrong on Church affairs for many years. Mr. Rader became a lawyer since the time I originally met him, and ever since he became an attorney he has been, as far as I know, a member of the Bar of the State of California. Mr. Rader has effective control over and responsibility for the legal affairs of the Church, and has had this control and responsibility for sev- eral years. Recently, in his capacity as Treasurer of the Worldwide Church of God, Inc.—a post to which he was appointed some months ago—he has taken financial re- sponsibility and control as well. 19. Mr. Herbert W. Armstrong is now eighty-six years old, and while he is still in possession of most of his fac- ulties, he is beginning to suffer from certain of the disa- bilities.of advanced age. Over the years, Mr. Rader has gained the confidence and trust of Mr. Armstrong to such an extent that recently, as far as I can perceive, Mr. Arm- strong no longer makes important legal or financial decisions himself, and is advised or influenced by few persons other than Mr. Rader. In consequence, it appears to me that as of this date, Mr. Herbert W. Armstrong is effectively guided by Mr. Rader in all Church matters and affairs. I declare under penalty of perjury that all the foregoing is true and correct. TABLE OF CONTENTS Summary of Pastor General Expenditures Summary of Pastor General Expenditures by Account Summary of Pastor General Expenditures by Month Graph of Credit Card Usage for Pastor General Travel § Lodging and Public Relations Pastor General Credit Card Usage in Detail Pastor General Travel and Lodging Expenditures by Month Pastor General Public Relations Expenditures Summary Pastor General Public Relations Expenditures in Detail Page 8 - 27 PASTOR GENERAL ~ SUMMARY OF EXPENDITURES July 1, 1975 Through June 30, 1976 ie Description Actual Budget Variance 2-510 Pastor General $1, 723, 930 $1,260, 000 $463,930 Over Budget 2-0511 P, G, Campaigns 136, 374 500, 000 363,626 Under Budget 2-1420 AICF tokyo 87,528 g 87,528 Over Budget Chancellor's Projects 83,811 d 83,811 Over Budget $2,031,643 $1, 760, 000 ' $271,643 Over Budget te? (wr * \~ c7e ks ce Ast Ue PASTOR GENERAL - EXPENDITURES July 1, 1975 Through June 30, 1976 Pastor : Thailand | Jerusalem] Jerusalem Pastor General AICF ICCY Mt. Tribe] Excav. S Excav. Chancellor's Account Totals General |Campaigns}| Tokvo Israel Program Wall Upper City | Scholarships Salaries $ 62,948 $ 62,948 Professional Fees (10, 460) 4,540|($ 15, 000) ; vrint Insertions 52 52 Telephone & Telex 12, 383 12, 383 Freight 5,997 1,184 4,813 Travei & Lodginy &89, 485 804, 927 83,185 |$ 1,373 Contracted Services 24,203 14,119 10,084 Maintenance & Repair 2,011 2,011 Outside Food Service 1,043 1,013 Ortice Supplies 919 919 Misc. Supplies 1, 669 1, 669 ’roduction Supplies 3,518 3, 344 174 Petroleum Products 461 461 Books & Periodica!s 12 12 Allocation to Branches 25,061 25,061 Property & Bldg. Rent 780 780 Insurance Premiums &, 500 2,530 Public Relations 819, 346 766, 422 52,924 All Other 9,882 10, 387 ( 638 ) 133 Employee Grants -in-Aids 120 $120 Grants-in-Aid 179, 713 10, 000 86, 022 $12, 500 $43, 391 $26,200 $1, 600 Het oe Totals $2,031, 643 $1,723, 930 $136, 374 |$87, 528 $12, 500 $43, 391 $26, 200 $1, 600 3120 | PASTOR GENERAL - MONTHLY EXPENDITURES July 1, 1975 Through June 30, 1976 Pastor Pastor General AICF Chancellor's Cost Center: General Campaigns Tokyo Projects Actual Budget Variance July 1975 $ 179,335 $ 47, 685 $ 9 $ 4,567 $ 231,587 $ 147,821 $ 83,766 Over Budget August 1975 195, 706 11, 704 g 5,366 212, 776 146, 431 66,345 Over Budget Sept. 1975 55,583 ) ) 30, 487 86,070 146, 431 60,351 Under Budget Oct. 1975 358, 653 ) 25,019 ) 383, 672 146, 431 237,241 Over Budget Nov. 1975 121, 828 ( 15,000) 10, 022 ") 116, 850 146, 433 29,583 Under Budget Dec. 1975 188, 169 13, 467 10,021 3,391 215,048 147, 823 67,225 Over Budget Jan. 1976 80, 691 9, 636 11,395 40, 000 141, 722 146, 433 4,711 Under Budget Feb. 1976 197, 058 13, 399 10, 022 g 220, 479 146, 433 74,046 Over Budget March 1976 36, 13a 10, 852 10,021 g 59,006 146, 441 87,435 Under Budget April 1976 81, 768 40,207 11,022 Y) 132,997 146, 441 13,444 Under Budget May 1976 89,078 1,272 5,016 ") 95,296 146, 441 51,145 Under Budget June 1976 137, 928 3,152 (5,010) y 136, 069 146, 000 9,931 Under Budget Total $1,723, 930 $136, 374 $87, 528 $83, 811 Thousands of Dollars 200 L1$0 30 : bor, 5 te — Mr. Mr. Mr. H. Cornwall H. Armstrong, Captatn Black, etc. S. Rader 0. Gotoh ——— Sep Oct Nov Dec Jan Feb . Mar Apr May Jin 75 75 75 75 76 76 76 76 76 76 CREDIT CARD USAGE FOR PASTOR GENERAL TRAVEL & LODGING AND PUBLIC RELATIONS Source: Expenditure Distribution Report - Monthly Payments to Credit Card Companies CREDIT CARD USAGE FOR PASTOR GENERAL TRAVEL & LODGING & PUBLIC RELATIONS oi i 8/75 9/75 10/75 -. 41/75 12/75 1/76 2/76 3/76 4/76 5/76 6/76 -E, 166.69 =$102,328.57 $1,381.88 $ 85,451.36 $26,553.71 $23,047. 46 $22,809.24 $ 40,721.63 $ 9,358.02 $31,401.63 $25,245.13 $64, 660. 35 ay. 82, O4 5,953. 40 9 120, 367. 72 23,299.05 75,157.63 19,597.00 $0, 752.32 °135,932. 97 1, 109. 34 16, 861. 96 18, 483.13 a; +. 10 1 765..53 g p g g 452.10 10,650.15 9,972. 76 526.13 g g Me ae at Y g Yy gabe g Yy 9, 180. 33 g g 39, 591. 46 d a. BT, t4+.83 $119,985.48 $1,381.88 $205,819.08 $49,852.76 $98,205.09 $52,038.67 $132,123.90 $33,263.75 $72,628.56 $42,107.09 $83, 143.98 ta. -r:dit Card Activity for Account Code #'s 6510-350, 6510-370, 6511-350, and 6511-370, respectively | $1, 027, 989. 07 ee OF oe Si4;:73:. 5 Y) $ 2,149.73 $ 1,627.00 $ 3,487.11 $ 1,705.02 $ 1,655.47 $ 2,669.54 $ 1,576.91 $ 3,648.91 $ 3,399.79 2,807.05 211,67 §$ 514.73 ¢g $ 2,149.73 $ 1,627.00 $ 3,487.11 $$ 1,705.02 $ 1,655.47 $ 2,669.54 $ 1,576.91 $ 3,648.91 $ 6,206. 84 tl sr:dit Card Activity for Account Code #'s 6510-350 and 6510-370 - Mr. H. Cornwall $25, 452.9 ee ee ee ae ae ~ eM RE AD ta a o—& - aoe i“ nw ited iinet nie ee i a . ee LRA ARN, WO, mee ee em See rte er ne ee o¥,°°11.69 3 90,769.27 $ 114.24 $ 68,512.16 $15,839.19 $11,507.58 $ 7,246.20 $ 23,528.27 $ 2,256.28 $20,365.95 $ 9,098.74 $30,886.57 5,953. 40 107, 687. 02 19, 003. 72 75,157.63 19,597.00 78,892.65 13,932.78 682.23 6, 730. 85 8,507. 57 me: 741.40 it, 703.51 452.10 10,650, 15 9,972. 76 526.13 ia , 9, 180. 33 . 39, 591. 46 15, 45.79 $108,426.18 $ 114,24 $176,199.18 $34,842.91 $86, 665.21 $36,475.63 $113,071.07 $26,161.82 $61,165.77 $15,829.59 $39, 394. 14 val credit Card Activity for Account Code #'s 6510-350, 6510-370, 6511-350, and 6511-370, respectively for Mr. O. Gotoh $313, 931. 53 ae a S.. Mie SS eee ee ae — ©,'55.25 $ 9,285.21 $ 257.37 $ 11,978.87 -$ 3,810.36 $ 5,356.06 $ 9,539.35 $ “2,334.69 $ 3,338.65 $ 4,627.41 $ 185.53 $ 2,749.53 13-4. 54 12, 680. 70 1,859. 47 427.11 10, 131.11 7,168.51 16, 0) 79 $ 9,285.21 $ 257.37 $ 24,659.57 $ 3,810.36 $ 5,356.06 $ 9,539.35 $ 4,194.16 $ 3,338.65 $ 5,054.52 $10,316.64 $ 9,918.04 tel + dit Curd Activity for Agcount Code #'s_ SR ee ee “ BR $1,759.46 $1,010.27 $ 2,810.60 $ 9,572.49" 3 ee: 3, eo 5 4,83) 36 $12 311 98 aon £ rs PASTOR GENERAL - MONTHLY EXPENDITURES ACCOUNT 350 - TRAVEL & LODGING July 1, 1975 Through June 30, 1976 Pastor General Month Pastor General Campaigns Amount Budget Variance : July $130, 380. 54 $47, 674. 10 $178, 054. 64 100, 416. 40 $ 77,638.24 Over Budget August 119,218. 80 11, 703.51 130, 922. 31 100, 416. 40 30,505.91 Over Budget Septernber 9,268.11 ) 9,268.11 100, 416. 40 91,148.29 Under Budget October 119, 682.00 ¢g 119, 682.00 100, 416. 40 19,265.60 Over Budget Novemiber 51,223.90 ; g 51,223.90 100, 416. 40 49,192.50 Under Budget December 50, 361.94 1, 814.20 52,176.14 100, 416. 40 48,240.26 Under Budget January 50,594.08 452.10 51,046.18 100, 416. 40 49,370.22 Under Budget February $5,971. 13 10, 650. 15 66,621.28 100, 416. 40 33,795.12 Under Budget March 23,909. 62 10, 365. 16 34,274. 78 100, 416. 40 66,141.62 Under Budget April $8,812.94 526.13 59, 339.07 100, 416. 40 41,077.33 Under Budget May 62,274. 00 ) 62,274. 00 100, 416. 40 38,142.40 Under Budget June 73,230. 74 g 73,230.74 100, 416. 40 . 37,185.66 Under Budget $804,927. 80 $83, 185. 35 $888, 113.15 ————— EXPENSE ANALYSIS SUMMARY PASTOR GENERAL EXPENSES - ACCOUNT 570 - PUBLIC RELATIONS * July 1, 1975 - June 30, 1976 (A) VIP Travel, Lodging & Entertainment (C) Film & Film Processing (E) Testimonial Dinners & Overseas Campaigns —= July $ 6,861.16 July $2,272. 64 July $ 4,600.00 Aug. 42,495.17 Aug. 536.02 Aug. 5,000.00 Sept. 7,385.93 Sept. 1, 419. 43 Sept. 4,420, 00 Oct. 91, 344.55 Oct. 153. 70 Oct. 107, 174. 10 Nov. (2,040. 42 ) Nov. Y) Nov. 23,177.60 Dec. 13,263. 18 Dec. 2, 178.10 Dec. 64, 840. 18 Jan. 7,056.24 Jan. d Jan. 28,261.27 Feb. 17,257.94 Feb. ") Feb. 106, 912. 37 Mar. 3,651.87 Mar. ¢ Mar. 15, 378.97 Apr. 8, 731.58 Apr. ) Apr. 39,591. 46 May 18, 927. 79 May ) May .- B June 11,314. 62 $226,249. 61 June i 6,559.89 June 3, 152.00 402,507.95 (B) Gifts (D) Contracted Services (F) Miscellaneous July $ 22,538.74 July $ 3,100.00 July $ g Aug. 6,961. 37 Aug. 24, 750.00 Aug. 65, 440. 00 Sept. 5,592.99 Sept. 7,000, 00 Sept. 13, 840. 00 Oct. 24,923.10 Oct. 104. 97 Oct. Y) Nov. 10, 845. 63 Nov. 2, 820. 02 Nov. 18,248.00 "/09/75 7/26/75 7/26/75 9/01/75 L. A. Hilton TWA - Gotoh TWA - Gotoh White Tie Limo.Serv. Diners Club - Rader Royal V.S. P. Services Am. Express - Gotoh TWA - Gotoh TWA - Gotoh TWA - Gotoh Beverly Wilshire Mrs. Mugo Kahala Hilton Am. Express - Gotoh Del Webbs Kuilima TWA - Gotoh Regency Hotel Hertz - L.A. TWA - Gotoh TWA - Gotoh Regency Hotel Purpose of Payment Senator Bunsei Sato Japanese Senators Flight Charges to San Antonio - Dr. & Mrs. Angeles Dr. Singh (7/31 - 8/05) Matsufuji and family and Dr. Ohno (8/28 - 8/30) Hajime Ishii (Japanese Diet) (8/25, 8/26) Misc. Expense - Japanese Delegates to Jerusalem Dr. Ohno (8-24 to 9-09) Yamaguchi Matsufuji Japanese Senators La Scala, Beverly Hills Honolulu Hyatt Regency - Manila Dr. Ohno Yamashita Mori B. Mugo (9/10 - 9/16) Bank Draft to Carlton Tower for Mrs. Mugo Ambassador Mugo & Family Imperial Hotel - Tokyo Hotel charges - Senator Matsufuji & Party - Hawaii Yomashita Mrs. Dottie Moore (10/20 - 10/21) s John Kineston for VIP ' Lloyd - NCE - Paris Yamaguchi Ambassador Mugo (9/2 - 9/10) ‘ Amount $ 904. 1, 997. 270. 1,774. 423. 180. 1, 835. $ 7,385. $ 1, 428. 2,054. 6, 734. 2,588. 195. 293. 3,926. 1, 041. 1, 355. 2,054. 2, 462. 4,972. 2,408. 5, 739. 476. 10, 660. 429. 422. 1, 695. 3,401. 5, 393. 60 EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 VIP’ Travel & Lodging (Continued): Invoice Date Recipient October (Cont. ): 3/20/75 TWA - Gotoh 10/06/75 White Tie Limo. Serv. 3/26/75 Amer. Express - Gotoh 9/17/75 Foreign Draft 3/20/75 TWA - Gotoh . 3/26/75 Amer. Express - Gotoh 9/25/75 Regency Hotel Sub Total for Amount paid in October Moveinber: 10/13/75 Perino's 9/18/75 Lowes Drake 11/15/75 Bev. Wilshire Hotel 10/01/75 Diners Club - Gotoh 11/19/75 Bev. Wilshire Hotel 9/03/75 TWA - Gotoh Sub Total for Amount paid in November Decernber:> 10/25/75 American Express 11/18/75 TWA - Gotoh 11/24/75 White Tie Limo. Ser. 12/20/75 White Tie Limo. Ser. 12/09/75 Royal USP Serv. 12/10/75 Royal USP Serv. 12/10/75 TWA - Gotoh 10/14/75 TWA - Gotoh 11/25/75 Regency Hotel, N.Y. Sub Total for Amount paid in December Purpose of Payment N,. M. Mugo ; Mugo & Family, Cornwall & Rader Korikawa Restaurant, L.A. Bank Draft to Carlton Tower, London Fukunaga Korikawa Restaurant, L.A. Dr. Singh (9/15 - 9/25) Various Meals Ms. C, Drake - Guest of H.W.A. - New York Sander, Gorlinsky Club Kon (Night club) - Japan Jascha Bistritzky (11/4 - 11/19) Senator Yamashita Osamu Gotoh - Hotel Bill - Switzerland Y. Olino - TYO - LAX - NYC - LAX - TYO Mr. George Whyte - Limousine Service Mr. Gotoh, Rader, Panov, Whyte Limousine Service in Hawaii Limousine Service in Hawaii Kabayashi - Paris to Tokyo J. Bistrytsky TLV - VIE, LON, NYC, - TLV Sara Kde Mekler - along with Bistrytsky de Amount $19,272. 921. 2,056. 3, 983. 1, 683. 67. . 98 4,020 73 65 84 64 50 91 $91, 344. 55 $ 298. 59. 1,175. 1,519. 1, 149. (6,243. 73 32 74 75 24 20) $( 2, 040. 42) > 6, 325. 1, 334. adi, 631. 423. 202. 2, 189. 1,465. 539. +0 77 80 25 20 60 29 24 63 $13,263. 18 10 (\) VIP Travel § EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 lodging ¢ Entertainment: January 1976: February 1976: Invoice ‘Date 12/30/75 12/31/75 12/30/75 12/29/75 12/02/75 12/19/75 01/07/76 12/18/75 12/14/75 12/18/75 12/16/75 10/25/75 12/05/75 01/26/76 01/28/76 01/25/76 01/31/76 12/24/75 12/16/75 01/14/76 12/24/75 01/14/76 12/23/75 Recipient Perino's Perino's Perino's White Tie Limo Serv. White Tie Limo Serv. White Tie Limo Serv. White Tie Limo Serv. TWA - Gotoh TWA - Gotoh TWA - Gotoh TWA - Gotoh Diners-Gotoh Diners-Gotoh Perino's Perino's White Tie Limo Serv. White Tie Limo Serv. Amex - Gotoh TWA - Gotoh TWA - Gotoh TWA - Gotoh TWA - Gotoh TWA - Gotoh Purpose of Payment Meals Meals Meals Mr. Cornwall §& Mr. Fujita - 5 trips Mr. & Mrs. Arthur Rubenstein Mr. Rader Mr. Rader - 3 trips F, Lloyd - Hong Kong-Zurich-Paris M. Lloyd - Tokyo - Hong Kong Akanoma - Hong Kong _ Akanoma - Tokyo-Hong Kong-Beirut-Cairo-Paris-London-New York Sub-total tor January S.A.Hermes - Paris (Credit) Japan (establishment unknown) Meals Meals Mr. Rader 4 party Mr. Gotoh S.A.Hermes - Paris Siniscar - Tokyo-Honk kong-Singapore-L.A.-Tokyo J. Romm - Tokyo-Paris Stanronides - London-L.A.-London S. Hagiwara - Tokyo-Paris-Tokyo ‘«. Y. Akgndiya - Cairo-Paris Sub-total for February Amount ; : ae y. sr; 344 461, 96, 28 149, 1,612. 8S. 334. 1,983. 60 16 64 70 60 .30 00 10 83 16 65 $ 7,056. 24 $ (750. 1,147. 226. 868. 212. 147. 2,257. 3,989. 1,646. 795. 6,584. 152. 38) 30 07 68 60 60 12 68 23 44 92 68 $17,257. 94 11 EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 (A) VIP Travel §& Lodging §& Entertainment: “arch 1970: April 1970: Invoice Date 02/20/76 02/25/76 02/28/76 Adjustment 01/29/76 01/31/76 02/19/76 03/05/76 03/12/76 03/18/76 03/19/76 03/21/76 93/23/76 03/27/76 03/29/76 03/30/76 03/31/76 04/01/76 04/17/76 Recipient White Tie Limousine Perino's Perino's TWA TA = Gotoh TWA - Gotoh White Tie Limo.Serv. White Tie Limo.Serv. Diners Club S.R.R. Diners Club S.R.R. Diners Club S.R.R. Royal VSP Serv. Diners Club S.R.R. Perino's Perino's La Scala White Tie Limo Serv. Ambassador Nasar Disneyland Tour Purpose for Payment Limousine Service - Gotoh Food Service - H.W.A. Food Service - S.R.R. Miyagawa Sub-total for March Miyagawa Kawada Horowitz Rader §& Cornwall La Scala La Scala La Scala Limousine Service in Hawaii Beverly Wilshire Food Service Food Service Restaurant - S.R.R. Ambassador §& Mrs. Nasar Expense money Ambassador Nasar Sub-total for April (A) VI Travel & Lodging & Entertainment: vilne Pe d Love: 19703 Invoice Date 02/10/76 02/25/76 02/25/76 02/25/76 02/25/76 02/25/76 02/25/76 02/25/76 02/25/76 02/25/76 03/13/76 04/02/76 04/07/76 05/06/76 05/13/76 04/06/76 05/16/76 05/16/76 Recipient Diners Club Diners Club Diners Club Diners Club Diners Club Diners Club Diners Club Diners Club Diners Club Diners Club Diners Club Perino's Perino's Beverly Wilshire Hotel La Scala EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 Gotoh Rader Rader Rader Rader Rader Rader Rader Rader Rader Gotoh Diners Club - Gotoh Amer. Express Amer. Express Purpose of Payment Imperial Hotel - Tokyo Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hilton Hotel - Jerusalem Hawn Regent Hotel - Honolulu Meals Meals Ambassador Nasr & Family Hotel Bill Meals - Rader Sub-total for May Hotel Plaza - Paris Canyon Hotel - Palm Springs, Mr. Cornwall Canyon Hotel - Palm Springs, Mr. Cornwall Sub-total for June Amount $ 2,473.38 1,084. 00 1, 323. 61 1, 084. 00 1,219.50 1,084. 00 1,084. 00 1,084. 00 1,084. 00 1, 084. 00 4,257.20 779. 36 36.17 1, 180. 88 69. 69 $18,927.79 $ 8,507.57 500. 04 2,307.01 $11, 314. 62 as 13 (:3) Gifts: July: Invoice Date 6/11/75 6/11/75 6/10/75 6/12/75 0/25/75 7/09/75 7/09/75 ee ee ee ee er ee eee ee ee EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 Recipient Amer. Express -.S. Rader Amer. Express - E. Black Lee Mac Camera Lee Mac Camera Steuben Glass ° Worldwide Adv. -Gotoh Worldwide Adv. -Gotoh Sub Total for Amount paid in July August: 3/22/75 7/28/75 $/12/75 7/29/75 7/19/75 7/02/75 8/06/75 Central Stores W/C Amer. Exp.- Gotoh Barnhart Lee Mac Camera Amer. Exp. -Gotoh Lee Mac Camera WWA - Gotoh Sub Total for Amount paid in August September: 9/09/75 §/29/75 8/19/75 WWA - Gotoh Lee Mac Camera Lee Mac Camera Su!) Total for Amount paid in September October: 8/31/75 7/09/75 8/23/75 8/27/75 8/27/75 2/27/75 10/2/75 10/9/75 9/12/75 Amer. Exp. - Rader Amer. Exp. - Gotoh Amer. Exp. - Gotoh Diners Club - Gotoh Amer. Exp. - Gotoh Amer. Exp. - Gotoh Steuben Glass Co. WWA - Gotoh Lee Mac Camera Purpose of Payment Sato Photo Co. King Fook Gold & Jewelry - Hong Kong Mr. Gotoh - 3 Cameras & Accessories Mr. Gotoh - 3 Cameras & Cases 1 Moses, 1 Pyramidon; 1 Excalibur, 3 Pillar of the Criffin Gifts for Tokyo, Geneva, Paris trip (6/16 - 6/25) Tokyo, Paris Monte Carlo trip Cross, Schaeffer, Parker Pen and Desk Sets Sato Photo Co. - Tokyo Golf Balls for King Leopold 4 Cameras, Accessories & Film Sato Photo Co. 6 Cameras & Accessories Egypt, Israel & Orient (8/1 - 8/20) Trip - Tokyo, Bangkok, Austria (8/21/75 - 9/21/75) Camera & Accessories 2 Cameras and Accessories Sato Photo Co., Tokyo Gucci Shop, Paris Sato Photo Co., Tokyo Gucci Shop, Beverly Hills * Gucci Shop; Beverly Hills Gucci Shop, Beverly Hills “° 4 Crystal Griffins Gifts for Geneva, Paris, Dusseldorf Cameras, Cases, etc. ee i eines . UR? or rey ee + eee te 14 Gitts (Continued): Octuber (Cont. ) Invoice _Da te 03/21/75 10/31/75 10/31/75 10/31/75 Recipient Diners Club Gene Michel . Central Stores, WC Central Stores, WC Sub Total for amount paid in October Noveniper: 10/20/75 09/30/75 11/12/75 09/25/75 Steuben Glass Co. Amer. Express--Gotoh Osamu Gotoh Amer. Express - Gotoh Sub Total for amount paid in November Deceniner: 00/03/75 19/98/75 10/15/75 10/27/75 10/27/75 10/27/75 10/27/75 10/30/75 11/14/75 12/26/75 12/23/75 12/01/75 12/03/75 ACUK Backcharge Amer. Express Carte Blanche Carte Blanche ‘Carte Blanche Carte Blanche Carte Blanche Diners Club American Express Osamu Gotoh Central Stores WC Osamu Gotoh Osamu Gotoh Sub Toral for amount paid in December EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 Purpose of Payment Expenses incurred in Japan ‘Golf Clubs Cross, Schaeffer, Parker Pen and desk sets (6/15 - 7/15) Cross, Schaeffer, Parker pen and desk sets (8/15 - 10/15) Four Pieces of Crystal Sato Photo Co. Gifts for Japan, Jamaica, Thailand, Incia, etc. King Fook Gold & Jewellry - Hong Kong / Mr. Rader - Perfume purchased at Harrods Osamu Gotoh - K. Mikinoto & Co. Tokyo Osamu Gotoh - 62 Pc. Flatware Osamu Gotoh - Mens Jacket Osamu Gotoh - Glassware Osamu Gotoh - Ladies Jacket Osamu Gotoh - Mens Jacket Osamu Gotoh - Christian Dior, Faris Osamu Gotoh - Duty Free Shop Cash paid out for gifts Pen and Desk Sets for Mr. Gotoh Gifts - Japan, Philippines, Thailand, Iran, Switzerland Gifts - Bahamas, Japan, Korea, Israel, Egypt, etc. ee Amount 921.94 111.40 1, 636. 78 1. 735.20 $24, 923. 10 $ 3, 406.00 1,502.50 5, 300. 00 637.15 $10, 845. 63 $ 81.27 1,666.95 55.88 22.76 36. 54 22.76 22.76 115.06 306. 85 209.88 442.66 4,600.00 5,000.00 $12, 583. 37 ——————ww EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT S70 — —— -- lé (g) Gifts Invoice * Date Recipient Purpose of Payment Amount January 197%: 12/01/75 Lee-Mac 2 cameras § cases $ 356.02 12/17/75 Amex - Gotoh Sato Photo Co. - Tokyo 516.06 12/23/75 Polaroid 11 cameras with cases 4 film 2,324.95 Sub-total for January $ 3,177.03 February 197o: 12/23/75 Diners - Gotoh Christian Dior - Paris $ 635.46 12/18/75 Diners - Gotoh Siberian Fur Store - Kowloon 2,124.24 01/15/76 Amfac 12 cases of flashbars 245.38 01/10/76 Amex - Gotoh K.K. Cosmo Tenchido - Tokyo 209.73 01/03/76 Amex - Gotoh Bernard's China - Nassau 309.05 01/09/76 Amex - Gotoh Sato Photo Co. - Tokyo 1,223.32 01/08/76 Amex - Gotoh Sato Photo Co. - Tokyo 245.13 12/23/75 Amex - Gotoh Cartier - Paris 1,560.78 Sub-total for February $ 6,451.09 Murch 1976: 01/23/76 Amex - Gotoh Nassau Shop - Bahamas $ 360.00 01/25/76 Amex - Gotoh Island Newsstand 156.00 01/30/76 Amex - Gotoh Sato Photo Co., Ltd. 1,138.00 02/03/76 Lee Mac Poloroid Cameras 2,646.00 02/03/76 ‘Lee Mac Leather Carrying Cases 245.36 Sub-total for march $ 4,545.36 April 1976: 09/15/75 Diners - Gotoh Christian Dior ; $ 258.04 02/04/76 Diners - Gotoh Gucci - Paris \ 682.23 . Sub-total for April $ 930.27 — ——- (33) Qifts Invoice Date 06/14/76 05/08/76 Recipient Patek Philippe Steuben Glass EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 Purpose of Payment Gifts - H.W.A. Purchase Six Crystal Pillar/Griffins Amount $ 4,504. 00 12, 020. 00 $16, 524. 06 17 ri.) Film & ily: Film Processing: Invoice Date 6/93/75 ° 6/12/75 Recipient Lee-Mac Camera Lee-Mac Camera “ib Total for Amount paid in July \ oe ‘ a? igust: ‘ptember: SSZAF 7S 8/29/75 8/05/75 8/07/75 7/30/75 8/04/75 8/25/75 7/22/75 8/07/75 7/22/75 Eastman Kodak Eastman Kodak Eastman Kodak Consolidated Film Ind. Consolidated Film Ind. Consolidated Film Ind. Consolidated Film Ind. Consolidated Film Ind. Consolidated Film Ind. Consolidated Film Ind. sab iotal for Amount Paid in September (i D > vo» Total “tober: cembdber: 9/03/75 Lee-Mac Camera Consolidated Film Ind. Consolidated Film Ind. American Express American Express for Amount Paid in December EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 Purpose of Payment Mr. Gotoh - 420 Rolls of Film § Bulbs Mr. Gotoh - 130 Rolls of Film §& Bulbs Mr. Gotoh - Film Film Film Film Film Film Film Film Film Development Development Development Development Development Development Development Color Processing Asian Asian Asian Asian Asian Asian Asian Film Expenses for AICF Film Expenses for AICF Osamu Gotoh - Photo Hall, Paris Osamu Gotoh - Sato Photo Co. Tokyo 36 Rolls of Film Students Students Students Students Students Students . Students Amount $1,583.64 689.00 106.48 $1,419.45 153.70 $ 193.65 16.92 56.02 La Rada ok $2,178.10 18 >. ptember: NoeVenber! Contracted Services: Invoice ate D 7708775 8/20/75 9/03/75 10/26/75 11/30/75 11/20/75 11/06/75 11/20/75 11/20/75 11/96/75 Recipient Hans Quast Gateway Hans Quast Sam Duncan San Duncan WC Adjustment WC Adjustment WC Adjustment WC Adjustment WC Adjustment Subd Total for Amount Paid in November EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 Purpose of Payment Brecht Translation Rights §& Art Design - Polydor Amount $ 3,100.00 Advance to Guarantee Payment - Book on Hirohito $24,750.00 Unicef - U.N. Record $ 7,000.00 Photography for Japanese Documentary 104.97 Photography for HWA Banquet TV - Audio Clip for Slide Presentation Tony Vanderleeden - Film Editing TV - Recording of AICF Performance TV - Use of Beethoven Recording at Recital 2-min. Talk Show - KNXT; KFAC l-min. 614.04 24.50 20.00 54.30 19.18 2,088.00 $2,820.02 (D) Contracted Services June 1976: Invoice Date Oo/21/76 05/21/76 EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 Recipient Gateway Publishers Gateway Publishers Purpose of Payment World Activities of United Nations & Introduction to Egypt World Activities of United Nations & Introduction to Egypt 20 Amount $ 2,300.00 17, 000. 00 $19, 300.00 EXPENSE ANALYSIS PASTOR GENERAL EXPENSES - ACCOUNT 570 (EE; Eanquets: [Invoice Date Recipient July: 7/09/75 Worldwide Adv. - Gotoh 7/99/75 Worldwide Adv. - Gotoh Sub Total tor Amount Paid in July Auwiust: 7/28/75 Worldwide Adv. - Gotoh 8/06/75 Worldwide Adv. - Gotoh $/7 3/73 Peter Schanz Sub foral for Amount Paid in August Sepytciber: 9/05/75 AC Food Service 9/09/75 Worldwide Adv. - Gotoh 9/03/75 Worldwide Adv. - Gotoh Sud Total for Amount Paid in September October: 7/17/75 Am. Express - Gotoh 3/03/75 Am. Express - Gotoh 38/31/75 Am. Express - Gotoh 9/12/75 Am. Express - Gotoh 9/11/75 Diners Club - Rad [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385006_1778%3A04. Public record. Not legal advice.