Professional Documents
Culture Documents
MiNISTRTES
(A Nevada Non-Profit Corporation) CIRCI.IIT COLIRT
Plahtiffs
SERVE ON: ,r
And
SERVE ON:
Christopher Akiaduro, Resident Agent
5506 Church Road
Bowie, Maryland 20720
And
LAWRE}{CE OLI"J-KTINMI
ADETTNJI
I 2806 Maidenwood Terrace
Beltsville, Maryland 2A7 05
And
KAYODE OJES/ALE
9520 Georgian Way
Owings Mills, Maryland ZlllT
And
ELERA hIWOGU
2512 Nicol Circle
Mitchellville, Maryland 2A7 2l
And
EMILOLA OKE
9701 Apolio Drive, Suite 301
Largo, Maryland 20774
And
KOFFI POSSIAN
1310 Fatima Place
Landover, Maryiand 207 8 5
And
MIRIAM A. MORGAN
7803 Desen Drive
fanham, MarJ,iand 207 06
And
QUADRI ADELEKE
7321 Powhayan Steet
Lanham, Maryland 207A6
And
RAYI\4OND AU/OSIKA
1623 Winesapp Drive
Odenton, Maryland 21 1 13
And
BEATRICE M, BOATENG
97170 Bridgeway
Mitche[ville, Maryiand 20721
And
CHRISTOPTMR O. AKI}I-DTIRO
13626 Wood Ember Drive
Upper Mariboro, Maryland 20774
And
ISRAEL O. ADETLINJI
12806 Maidenwood Terrace
Beltsville, Maryland 207 05
And
RONKE O. ADETLNJI
12806 Maidenwood Terrace
Beltsvilie, Maryland 207 05
And
ESTT{ER A. ADETUNJi
12806 Maidenwood Terrace
Beltsville, Maryland 20? 0 5
Defendants
FrRcusoN, Scurreltcu & Baltrw, P.A., Thomas J. Scheteiich and Rafiq R Gharbi, bring
this action compiaining against CHRIST THE TRUTH MINISTRES, INC., MOLNTAiN
GENERAL ALLEGATIONS
Nigeria-
relations of Mountain of Fire and Miracies Ministries churches in the United States, and
being the beneficiary of ali real and personal properry of such churches that disassociate
under the name of "Mountain of Flre & Miracles Mi:listries" and which fiied Articles of
Amendment on May 23, 2A02 changed its name to "Mounrain of Fire & Miracles
reiigious purpose is the propagation of the fuii gospei of Jesus Christ throughout the world;
to encourage believers to receive the baptism in the Holy Spirit and Fire, and to lead people
pafi" has a cent'ai governing body that acted regularly withia its powers. MOFMM,
ministry is directed through a series of Regional Overseers, who oversee the local churches.
Roa4 Bowie, Maryland by deed dated August16,2001. This property consists of 12 acres
(more or less) on which is constructed a church building, parking lo! and other
improvements.
Church Road Bowie, Maryiand by deed dated September 29,2004. This properry consists
10. All of the real property. tangible personal properqv, and intangif,le personal
11. The terrns of the tru$ were established by the docrtments of MOFMM,
aliegations foUowing.
12. It'2002, General Overseer Olukoya distributed a written direction from the
submit affidavits declaring their ioyalty to the ministDz, srating .they hold the church for
and on behalf of the MFM headquarters" and that "under no situation wiU they split the
congregation, seize its assets, or handle the church as a personal property." LAWREI';CE
Agreement inciuding that he would "ho1d this church in trust for and on behalf of Mountain
Olukoya-
and obey all the policies, procedures, mles and regulations governing the
Mountain of Fire
Ministies established by the General overseer. He further agreed that "ail records
of the
accounts of your Branch, records, books, programs, whether maintained
in physical or
eiectronic media, relating in uoy manner to Mountain of Fire and Miracles
Ministries,
behalf of the Branc[ demographic or econonn-ic data whether prepared by the Branch
or
otherwise seming into tle Branch's possession, should be the exclusive properfy of
Mountain of Fire and Miracles Ministries, U.S.A., regardless of who acfualiy purchased
16- The appointnent firther required LAWRENCE ADETIINII that .,all such
books, records and compirter flies sha-ll be immediately retr.rmed. to Mountain of Fire
and
Miracles Minist.ies, U.S.A., by the Branch on any termination or succession (sic) of the
Branch from Mountain of Fire and Miracles Ministries, u.S.A." The letter of appointuent
firther stated that he would "hold this Branch, this Churcb, and all its properry in trust for
and-on-behalf of Mountain of Fire and Ministries, U.S.A.,,
17. The appointn:ent letter of october 27, 2012 was signed by LAWRENCE
and MOFMM, USA; and that he wouid guirie and oversee MOFMM, MARrLAND to
assure that 'lhe Coqporation and its Officers will hold this Church and its property
in tnrst
shall give the General Overseer and the Regional Coorriinator a min.imum
of thirfy (30)
days'notice of my intent to withdrawal.,,
that "it shali conduct all business in accordance with the directions, instuctions,
constitutions, cannons (sic) and rules of Mountain of Fire anii Miracles Ministries
laternational and ia General Overseer.,,
20. The same amended By-laws provided that'tle property of Mowrtain of Fire
in trust on behalf and in favor of Mountain of Fire & Miracles Ministries lnternationa]
and
the General Overseer Daniel Kay Olukoy4 by the Unites States Headquarters, Mountain
21. The sarne amended By-laws srated that "Mountain of Fire and Miracles
agrees that any and all properly held in trust on behalf of Mountain of Fire and Miracles
Ministries lnternational shail be, upon reasonable request or upon the winding up or
dissolution of this Corporation be provicled to and tumed over to Mountain of Fire and
understood that Mor:ntain of Fire and Miracles Minimies Lrternational and/or the General
overseer andTor any other person designated by Mountain of Fire and Miracles Ministries
lnternational and/or the General Overseer may appoiat, assign or select any person
on
behalf of the International Ministry, to accept any and all properties held in Trust on
behalf
22. On March 8, 2014, MOFVIN,{, Maryland amended and restated its Arcicies
of lncorporation, inciuding adding a new Article Five which stated that upon the winding
up and dissolution of the religious corporation, its assets "shall be distibuted to Mountain
of Fire and Miracles Ministies lnternational by and through t}le Intemational Ministries
United States Headquarters, Mountain of Fire and Miracles Minisries lnc. a Nevada non-
profit Corporation."
Mountain of Fire and Miracles Minisries, i:rternational by and through its headquarters in
the united States, its Nevada non-profit corporation named N46unrain of Fire and Miracles
which stated: "On dissoiution, for whatever reason, all assets remaining after payment of
the debts of the Corporation shall be distributed to Mountain of Fire and Miracles
Mrniskies lnternational, through its headquarters in the United States, Mountain of Fire
25. The same Restated Articies of lncorporation required that certail actions
Adopting, or Repeaiing the By-laws of the Corporation; and d.issolving the Corporation.
26. The Restated Articles of lncorporation were adopted on March 8, 2014, and
were fiied with the Maryland State Departuxent of Assessments and Taxation on April22,
201,4.
and MOFIv[kI, LrSA of thek interest in the reai properfy, tangible personal property, and
real property, tangible personai proper[v, and rntangible personal prcperfy to another
religious corporation under their contol, and to deprive the congregation of MOFIv[I4,
and its Trustees to hold the reai properry, Angible personai property, and intangible
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personal property of the religious corporation in tnrst for the benefit of MOFIvIVI,
30. The December, 2015 Articles of Amendment and Restatement were not
31. The December, 2015 Articles of Amendment and Restatement were not
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Maryland Departnent of Assessments and Taxation"
iNTERIIATIONAL but would now be an independent church under the narne CHRIST
Defendzrnts had the church signs bearing the name "Mountain of Fire Mirristries" removed
ownership of the name "Mountain of Fire & Miracles Ministries of Bowie, Maryland..,'
38. By the letter of March 30,2016, MOFIvII\4, USA, through its iegal counsel
Gilbert Garci4 demanded that the defendants cease and desist in their wrongfirl conducf
and convey all property pursuant to the terms of the trust and the vaiid colporate
docr:ments.
39. No substantive response has been received in response to the letter of March
30,2016.
40. The real properff located at 5503 and 5506 Chwch Road. Bowie remains
titled to MOFMM, MARYLAND and has never been distributed by its Trustees or to
41. The real property located at 5503 and 5506 Church Road, Bowie is being
t2
used by CHRIST THE TRUTH MbIISTRIES and the individual Defenda:rts, in violation
to these Piaintiffs.
42. The tangible personal property of MOFIvOvt, IvLARYLAND has never been
43. The tangible personal properly located at 5503 and 5506 Church Road,
Bowie is being used by CHRIST TT{E TRUTH MINISTRES and the individual
CHzuST THE TRUTH MII\]ISTzuES and the ind"ividual Defendants, for their own benefit
and enrichment.
COTNT ONE
DECLARATORY JLTDGMENT
AG{NST DEFENDANTS CI{RIST THE TRUTH
MIMSTRIES AIVD MOFMM. MARYLANT'D
47. This action 15 sysrght purswmt to Maryiand Code, courts and Judicial
real properfy, tangible personal property, and intangible personal properfy, titled ir
11
IJ
MOFIv[N4, MARYLAND"
49- An actual controversy exists, antagonistic claims are present as between the
parties, and the Plaintitrs are asserling a legal stafus, right, and priviiege
that is challenged
and possession ofthe real properfy, tangible personal propeffy, intangible personal properry
50. The real properry, tangible personal properry, and intaagible personal
A. Enter a Declaratory Judgment that the real property known as 5503 Church
Road and 5506 Church Road, and the tangible personal properry and intangible personal
B. Order the costs of this proceeding, and legai fees incr.rred by Piaintiffs to
COUT{T TWO
BREACH OF TRUST AND }-TDUCIARY DUTY
AGAINS T IIVDI\TID UAL DE FENDANTS LA WRENCE ADE TLNJI, KAY ODE
CJf,WALE, CHRTSTOPI{E,R OKTVDURO, ELERA ]VWOGU, EMILOLA OI(8,
KOFF'I POSSIAN, MIRIAM MORGAN, QUADRI A.DELEICO,
RAYMON'D AWOSIKA A}TD BEATRICE BOATENG
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52. lhe real property, tangible personal property, and intangible personal
properfy titled in MOFMM, MARYLAND was heid in trust by Trustees, the Defendants
54. The terms of the trust established in the corporate documents of MOFMM,
MARYLAND provided that upon dissolution of the religious corporation ali real properry,
55- In violation of the tust provisions and in breach of their fiduciary duties,
the individual Defendants named in this Counl have failed and refused to distribute the
real properfy, tangible personal properry, and inungible personal property to MOFMM,
56. ln violation of the trust provisions and in breach of their fiduciary duties,
the individual Defendants named in this Coun! have distributed the tangible personal
and have permitted CHRIST THE TRUTH MnIISTR-ES to make use ofthe realproperty.
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OKE, KOFFI POSSIAN, MIRIAJVI MORGAN, QUADRI ADELEKE, RAYN{OND
AWOSIK,A" AND BEATzuCE BOATENG have each violated the ft'ust provisions and
breached their fiduciary duties, for which each is personally iiable and accountable.
PlaintiffslPetitioners.
the individual Defendants narned in this Count, in such amount as may be shown by the
D' Assume jurisdiction over the administration of the assets titled to MOFMM.
MARYLAND or its t-ustees held i:r trust, and administer the same in accordance with the
COUNT THREE
PETITION FOR APPOINTMENT OF RECEI\TER AGAINST
MOFMM, MARYI,AND AIYD INDTWDUAL DEF'E]VDANTS
LAWRENCE ADETUNJI, KAYODE OJEWALE,
CHRISTOPMR AKINDI,IRO, ELERA IYWOGU, EIVtrLOLA OIG,
KOFtrI POSSIAN, MIRTAM MORGAN, QUADRT ADELEI(E,
RAYMOND AWOSIKA A]YD BEATRICE BOATENG
58. Good cause exists for this Court to assume jurisdiction and supervise the
15
liquidation of the assets titled to MOFMM, MARYIAND, or its trustees, pursuant to
59. The cause for Court supervision of the liquidation and distribution of the
assets of the religious corporation are that the real properry, tangibie personai property, and
intangible personal properfy titled to the religious coqporation or to its trustees, have not
been distibuted pursuant to the terms of its corporate docr:ments or the law.
COLNT FOUR
TROYER AND COI.IYERSION
AGAINST CHRIST THE TRUTH MINISTRMS AND INDI\TIDUAL
DEFEI\'DANTS LAWREN CE ADETLNJI, CHRTS TOPHER AKIND {,IRO
ISRAEL ADETUNJI. ROI{KE ADETT.]-I{JI AND ESTTTER ADETT]NJI
61. The taking of'the tangible personal assets titied to MOFMM, MARYLAND,
17
intentional exercise of dominiea and conhol over tangible personal property belonging
to
al]d ESTIIER ADETLINJI remain in possession and control of the ungible personal
$75,000.
COU}IT FrrE
CTWL CONSPIRACY
AGAINST INDTWD UAL D EFENDANTS LAWRE]VCE ADE TI.INJI,
CHRISTOPT{ER AKNIDTIRO, KAYODE OJEWALE, ELERA NWOGU,
ENILOLA OKE, KOFTI POSSIAN MIRTAM MORGAN, QUADzu ADELEKE
RAIMOND AWOSIKA' BEATRICE BOATENG ISRAEL A-DETLINJI, RONIG
ADETUNJI A]VD ESTIIER ADETTNJI
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AKINDIJRO, KAYODE OJEWALE, ELELA NWOGU, EMILOLA OKE, KOFFI
PlaintitrslPetitioners of their interest in the real property, ta"gible personal property. and
66. As a result of the actions of these Detendants, acting in concert, the real
properry, tangible personal properly, and intangible personal properfy that should be
distributed to PlaintiffslPetitioners has instead been distributed to, taken by, and"/or made
67. The actions of these Defendants, and each of them, were knowing,
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ESTHER ADETINJI for punitive damages in ttre arnount of $250,000 each.
COUNT SIX
CONCEALMENT
AGAINS T INDTVID UAL DEFENDANTS LAWREN CE ADET{ ]}[JI,
CHRISTOPHER AI(NDURO, KAYODE OJEWALE, ELERA NWOGU,
EMILOLA OKE, KOFFI POSSIAN, MIRIAM MORGAN, QUADRI ADELEKE,
RAY}IOND AWOSIKA, BEATzuCE BOATENG, ISRAEL ADETUNJI, RONKE
ADETTINJI AI\ID ESTI{ER ADETUIYJI
agreemnt to disclose the actions detaiied in this Complaint and Petition to MOFMM,
71. The failure to make disclosure was done with the intent to deceive
P iaintiffslP etitioners.
2A
72. PlaintiffsPetitioners acted in justified reliance upon 1fos ssnsealment.
COTIIYT SE\EN
F'RAUD
AGAINS T DEFEI\'DANT LAWREN CE ADETTINJI
Plaintiffs were false when made; and to the extent they were promises of future
21
75. Defendant LAWRENCE ADETTNJI knew that the representations were
COTNT EIGHT
EJECTMENT
AGAI}{ST DEFENDANTS CHRIST TIIE TRUTH MINISTRIES
AND LAWRENCE ADET{.]NJI
80. CHRIST TI{E TRUIH MhISTRIES has wrongfirliy entered upon and is
i:r possession of the real properly known as 5503 Church Road and 5506 Church Road,
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Bowie, Maryland.
properfy known as 5503 Church Road and 5506 Church Road, Bowie, Maryland, without
right to do so.
damages.
ZJ
Respectfuily submitted,
By,
{"e
100 S. Charles Strcet, SLrite i401
Baltirnore, Maryland 21 ZA t -2725
(410) 837-2200 * phone
(410) 837-1188 - facsimite
tschetel ich@fsb- law. com
rgharbi@f'sb-Iaw.com
A r t c rneys fo r P I a i n t iffs,
L.1