UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
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Three Angels Broadcasting Network, Inc.,
an Illinois non-profit corporation, and
Danny Lee Shelton, individually,
Plaintiffs,
v.
Gailon Arthur Joy and Robert Pickle,
Defendants.
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Case No. 07-40098 FDS
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AFFIDAVIT OF MOLLIE STEENSON
| STATE OF ILLINOIS | ) |
| ) |
| FRANKLIN, ss. | ) |
Mollie Steenson, being first duly sworn upon oath, deposes and states as follows:
I am the General Manager and the elected Secretary
of the Corporation and of the Board of Directors of the non-profit
corporation 3 Angels Broadcasting Network ("3ABN"), duly organized
in the state of Illinois. I have worked in the employ of 3ABN
since 1995. Through the duration of my tenure, I have worked
as an assistant to Linda Shelton, an assistant to Danny Shelton
and now have the position of General Manager. My duties as General
Manager include monitoring and managing the day-to-day operations
of 3ABN, acting as the human resources department, staying apprised
of the general financial condition of 3ABN, acting as the corporate
spokesperson and all of the duties as Secretary as described
in the bylaws below.
[page 2]
The duties of the Secretary for the Corporation
and for the Board of Directors, as defined in the revised bylaws
signed on September 14, 1997, are:
Section 5.6. Duties of the Secretary. The secretary shall act
as secretary of the corporation and the Board of Directors, shall
send appropriate notices or waivers of notice regarding board
meetings, shall prepare agendas and other materials for all meetings
of the Board of Directors, shall act as official custodian of
all records, reports and minutes of the corporation, the Board
of Directors and committees, shall be responsible for the keeping
and reporting of adequate records of all meetings of the Board
of Directors, and shall perform such other duties as are customarily
performed by or required of corporate secretaries including countersigning
all papers, including promissory notes of the Corporation in
writing that may require the same.
At Board Meetings, I review the financial statements
prepared by Chief Financial Officer Larry Ewing. These financial
statements contain an analysis of 3ABN's current financial status,
including donations, other revenue and expenditures.
Based on correspondence from donors and from financial
statements prepared by Larry Ewing, it is clear that donations
to 3ABN have decreased substantially since June 2006, when the
Internet commentary disparaging 3ABN and Danny Shelton erupted
on various sites on the Internet. Contributions have continued
their decline during the first quarter of 2007, coinciding with
Defendant Joy's operation of his website devoted solely to defaming
Plaintiffs at www.save3ABN.com. In fact, Defendant Joy stated
in a post at www.maritime.com sometime on our around November
20, 2006, that "[i]f [the attempt to resolve the matter before
ASI, a religious tribunal] does not work out, then in January,
2007 we will launch a full scale and public effort to exonerate
Linda, to indict Danny in the public eye and to put pressure
on 3ABN. . . ." See
http://www.blacksda.com/forums/index.php?s=792dcc3c96a3269a06da5ef966fe4cb2&sh owtopic=11142&st=105&p=158721&#entry158721.
[page 3]
I have received communications from past donors
that state that those donors are no longer donating to 3ABN specifically
because of the disparaging statements about 3ABN and Danny Shelton
on the Internet. Based upon the rumors spread across the Internet
on www.save3ABN.com and other sites, these donors have been led
to believe that 3ABN is no longer a reputable institution and
that Danny Shelton should be removed from his position at 3ABN.
See Attachments
A-F.
A letter published on Adventist Today1 on May 1, 2007, directly
cites to www.save3ABN.org (which directs the user to www.save3ABN.com)
as its source for some information. This letter charges 3ABN
with various alleged wrongdoings and concludes by making it known
that the writer has stopped all financial support of 3ABN. According
to the letter, many other donors also made this decision to stop
financial support of 3ABN for the same reasons as the writer.
See Attachment G.
The letter published on Adventist Today on May 1, 2007, also
alleges that Danny Shelton has committed many possible wrongdoings,
committed questionable acts, jeopardized the charitable standing
of the ministry, used donations for personal benefit and possibly
committed adultery. See
Attachment G.
3ABN received a copy of the letter published on
May 1, 2007, on Adventist Today through one if its supporters.
That supporter stated that in the future, she would be withholding
donations from 3ABN because of the allegations that are being
spread across the Internet, which had, in her opinion, placed
3ABN and Danny Shelton in a negative stance in the public eye.
See Attachment
H. I have received similar
1 Adventist Today (ISSN 1079-5499) is a bimonthly magazine publication of the Adventist Today Foundation that "reports on contemporary issues of importance to Adventist church members." As a companion to its printed publication, Adventist Today operates an internet website at www.atoday.com, and regularly publishes an electronic newsletter called "ATNewsbreak," which it distributes via e-mail.
[page 4]
correspondence from other supporters and donors
that express this same belief that, as reported on www.save3ABN.com
and other websites, 3ABN and Danny Shelton have done improper
things. Because of these beliefs, these donors now withhold support
and donations from 3ABN. See
Attachments A-F.
The website www.save3ABN.com also has contributed to a loss of
fundraising ability and 3ABN's ability to spread the Christian
message in the South Pacific. The General Conference of the South
Pacific Division of the Seventh-day Adventist Church has passed
a moratorium that prohibits any interaction with 3ABN. In effect,
this moratorium prevents 3ABN from sending speakers to churches
located in Australia, New Zealand, and the South Pacific. It
also prohibits any church employees in that region from creating
programming for 3ABN. This moratorium acts as a general bar to
any interaction between 3ABN and Seventh-day Adventist Churches
in Australia, New Zealand and the South Pacific. Based on my
knowledge and belief, the allegations posted on www.save3ABN.com
and other websites are what prompted the South Pacific Conference
to enact this moratorium against 3ABN. See
Attachment J.
In January 2007, postcards advertising www.save3ABN.com were
sent to Seventh-day Adventist Churches. From all indications,
the postcards were mailed to Seventh-day Adventist Churches across
the world. The postcards request recipients to view www.save3ABN.com.
The postcards also state, "It should be pointed out that 3ABN
is not currently part of the Seventh-day Adventist Church, and
never has been." The postcards do not contain any disclaimer
to signify that 3ABN is not related with www.save3ABN.com in
any way. In fact, the postcards imply that 3ABN is associated
with www.save3ABN.com. See
Attachment K.
[page 5]
I have been forwarded correspondence from a 3ABN supporter who
emailed www.save3ABN.com to verify whether the website was connected
to 3ABN. See
Attachment I.
The website www.save3ABN.com has previously posted letters and
other correspondence on its website. However, many times only
select portions of the documents are posted, misleading readers
into believing the documents stand for propositions other than
what the authors intended. Even when whole documents are posted,
comments are inserted throughout effectively directing readers
to draw inaccurate and defamatory conclusions from the documents.
If Defendants are not prohibited from publishing the legal documents
filed and/or served in this proceeding on www.save3ABN.com or
otherwise, then the Defendants will undoubtedly publish them
along with defamatory commentary and conclusions, thereby utilizing
this litigation as a vehicle to further tarnish the reputations
of 3ABN and Danny Shelton and to hinder 3ABN's ability to fundraise
and conduct its ministry.
FURTHER YOUR AFFIANT SAYETH NOT.
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Dated: May 9, 2007
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[signed] Mollie Steenson
Mollie Steenson
General Manager and Secretary
for 3ABN, Inc.
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Subscribed and sworn to me
this 9 day of May, 2007
[signed] Lynda E. Welch
Notary Public
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