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01-RIC482762 Initial Complaint of New Hope and Southern California AG District Counsel Filed Case-RIC482762 2007-10-11

01-RIC482762 Initial Complaint of New Hope and Southern California AG District Counsel Filed Case-RIC482762 2007-10-11

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Published by apharkletoshagio
New Hope files it's complaint against Ken Peters and Alan Spitalnick and anyone else who claims the property of New Hope.
New Hope files it's complaint against Ken Peters and Alan Spitalnick and anyone else who claims the property of New Hope.

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Published by: apharkletoshagio on Jul 10, 2008
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05/09/2014

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(L H*
OCT 112007
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Michael J. Collins, Bar No. 65506Julian B. Bellenghi, Bar No. 129942COLLINS & BELLENGHI, LLP1201 Dove Street, Suite 570Newport Beach, CA 92660Telephone: (949) 851-9311Facsimile: (949) 851-9333Attorneys for Plaintiffs
//
SOUTHERN CALIFORNIA DISTRICT COUNCIL OF THE^ASSEMBLIES OF GOD, aCalifornia Non-Profit Religious Corporation; and NEW HOPE FAMILYWORSHIP CENTER, a California Non-Profit Religious CorporationSUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF RIVERSIDE - WESTERN DIVISIONRIVERSIDE BRANCHCASE NO.^r'o
COMPLAINT FOR:1. QUIET TITLE
2.
DECLARATORY RELIEF3. ACCOUNTING
SOUTHERN CALIFORNIA DISTRICTCOUNCIL OF THE ASSEMBLIES OF
GOD,
a California Non-ProfitReligious Corporation; and NEWHOPE FAMILY WORSHIP CENTER, aCalifornia Non-Profit ReligiousCorporationPlaintiffs,v.KENNETH M. PETERS, JR.; ALAN R.SPITALNICK; ALL PERSONSUNKNOWN, CLAIMING ANY LEGAL OREQUITABLE RIGHT, TITLE, ESTATE,LIEN,OR INTEREST IN THEPROPERTY DESCRIBED IN THECOMPLAINT ADVERSE TOPLAINTIFFS' TITLE, OR ANY CLOUDON PLAINTIFFS' TITLE THERETO;and DOES 1 to 500, inclusive,Defendants.Plaintiffs SOUTHERN CALIFORNIA DISTRICT COUNCIL OF THEASSEMBLIES OF GOD, a California Non-Profit Religious Corporation, andNEW HOPE FAMILY WORSHIP CENTER, a California Non-Profit ReligiousCorporation, allege as follows:1
COMPLAINT
 
3
1. Plaintiff, SOUTHERN CALIFORNIA DISTRICT COUNCIL OF THEASSEMBLIES OF GOD [hereinafter DISTRICT
COUNCIL],
is now, and at alltimes mentioned herein was, a California non-profit religiouscorporation with its principal location at 17951 Cowan, Irvine,located in the County of Orange, State of California and doing itsbusiness in the County of Orange and State of California.
2.
DISTRICT COUNCIL is, and at all times mentioned herein was,a regional governing body of the Assemblies of God
[AOG],
ahierarchical religious organization. In that regard, DISTRICTCOUNCIL has governing authority over certain AOG affiliated churchesin a specific geographic area, which includes Corona and other areasof Southern California.3. Plaintiff, NEW HOPE FAMILY WORSHIP CENTER [NEW HOPE] is andat all times mentioned herein was, a California non-profit religiouscorporation and an AOG affiliated church operating under thejurisdiction of DISTRICT COUNCIL.
4.
At all times relevant herein, NEW HOPE, has conducted itsreligious services and related activities at certain real property[hereinafter "the Property"] located at 803 South Lincoln Avenue,
Corona,
California
92882,
legally described as:Parcel 3, as shown on Record of Survey on file in Book 42page 15, of Records of Survey, Records of Riverside CountyCalifornia:EXCEPTING therefrom that portion granted to the City ofCorona in deed recorded April 1, 1965 as instrument No.37481 of Official Records of Riverside County, California.5. Since on or around November 4, 1997, NEW HOPE has been
COMPLAINT
 
o
record title holder of the Property in fee simple, by virtue of agrant deed recorded that date as Instrument No. 402488 of theOfficial Records of Riverside County.6. Under DISTRICT COUNCIL'S Constitution and Bylaws, any realproperty held by a church under its jurisdiction is held in trust forDISTRICT COUNCIL. Should said church disaffiliate from AOG, title tosaid property reverts to DISTRICT COUNCIL.
7.
Defendant, KENNETH M. PETERS, JR. [PETERS] is anindividual, over age 18, and at all times relevant hereto was, and
is,
a resident of the County of Riverside.8. Defendant, ALAN R. SPITALNICK [SPITALNICK] is anindividual, over age 18, and at all times relevant hereto was, and
is,
a resident of the County of Riverside.9. Up to on or around August 9,
2007,
PETERS was the dulyappointed pastor of NEW HOPE and a minister duly authorized by AOGand holding an AOG ministerial credential.
10.
On August 9,
2007,
PETERS renounced his AOG ministerialcredential, rendering him ineligible to serve as pastor at NEW HOPEor at any other AOG affiliated church under the Constitutions andBylaws of both DISTRICT COUNCIL and NEW HOPE.
11.
Up to August 15,
2007,
SPITALNICK was a corporate officerof NEW HOPE.
12.
In or around August
2007,
PETERS, SPITALNICK, and othersacting in concert with them, some of whom purported to be members ofthe NEW HOPE'S board of directors and/or corporate officers,attempted to disaffiliate from AOG, and obtain possession and control
of,
and assert an ownership interest in, NEW HOPE'S assets,
COMPLAINT

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