IMPORTANT: 2/19 Follow-Up at end of this Article THE BOB LARSON SAGA CONTINUES - Ken Smith ============================================================== NOTE: Detailed documentation - provided by Ken Smith, and thoroughly supporting his allegations - is on file with Christian BBS Abba II's co-sysop, Anton Hein (publisher of the Christian Press Report). Abba II is dedicated to Christian Apologetics - a reasonable defense of the Christian faith. We do so by providing: - high-quality text files on Christian doctrines - articles that teach Christians "how to give an answer" (see 1 Peter 3:15) - Information on how to counter and refute cultic and aberrant teachings - Holding aberrant teachers accountable In addition, Abba II aims to provide up-to-date news and information of interest to Christians. Please be assured that we would not have made this article available for downloading if we did not also have the appropriate documentation. Also, while Bob Larson has been confronted with regard to the issues discussed here (by private individuals, as well as in major Christian publications) we consider his failure to respond in a satisfactory manner reason enough to alert Christians to his behavior. ============================================================== PRESS RELEASE THE BOB LARSON SAGA CONTINUES - Ken Smith In 1991, Horizon Broadcasting Corporation owner Garyl Gibson became concerned about the situation at Bob Larson Ministries, amid reports that Larson was pawning off pre-recorded shows as live, using grossly deceptive fund-raising tactics, and had one of his attractive female assistants write "his" novel for him on Ministry time. Other reports surfaced regarding infidelity and far worse; Gibson took it upon him self to investigate them. Finding cause for concern, Gibson sought the aid of former Watchman Fellowship staffer Fred Wheeler. But when they attempted to confront Larson in accordance with Matthew 18, he steadfastly refused to meet with them. Gibson cancelled Larson's radio program, "Talk-Back With Bob Larson," from his WHLV broadcast schedule,1 and Wheeler made the fruits of their investigation available to the media. (Their efforts precipitated an article in Westword magazine,2 and provided the foundation for subsequent articles.) I joined forces with the Wheeler group in June of 1992, when former Ministry vice-president Lori Boespflug furnished me with compelling evidence that the Westword reports were devastatingly accurate. In turn, I forwarded information to Christianity Today, various radio station owners, and EFICOM. Other stories followed, and Larson suddenly found a desperate need for a scapegoat. He couldn't attack Wheeler, who has a simply sterling reputation within the Evangelical community; as an unbeliever, I was the most obvious candidate. And Bob went after me ... with both barrels. He even hired a private investigator in the hope of discovering information which, in his own words, he could use to "put some heat" on me.3 On his radio broadcasts, Larson accused me of a litany of criminal acts, refusing to identify me by name upon the apparent advice of his attorneys. Those associated with the Larson investigation knew precisely who he was talking about, but as I was a private person, with no media access to speak of, there really wasn't a lot I could do to stop him. And he continued this assault in the media, private correspondence, and in all likelihood, on the Prodigy computer service.4 I finally confronted Larson on radio shows in both Wichita and Fort Lauderdale -- stating that the allegations against him were supported by "signed contracts, ... divorce transcripts, documents signed under penalty of perjury, ministry tax returns, and internal ministry memos provided by [his] own employees."5 But instead of dealing with the issues I raised honestly and forthrightly, he attacked me personally, accusing me of harassing him, "fabricating" court documents, and most notably, "stalking" him.6 As you might expect, I sued him for libel. This statement addresses (1) the public charges against Bob Larson, and their basis in fact, and (2) the lawsuit precipitated by his vindictive and cowardly assault upon my character. I. The Charges The charges against Bob Larson haven't changed; the only difference is that evidence supporting them is now absolutely overwhelming. Bob can only run from those who would inquire: When Anchorage television station KTUU recently asked about the money he had made from the Ministry, he immediately terminated the interview.7 Not only does Bob appear guilty -- he acts guilty. A. Ghost-Writing by BLM Staffers The most incriminating evidence with respect to the ghost-writing by former BLM vice-president Lori Boespflug is a July 8, 1991 letter from Larson's former attorney, Bill Abbott. Abbott's advice to Lar son speaks for itself: "You will be required to write more, but after all, it is you who will enjoy the benefits."8 Bob Larson has publicly claimed that the letter was "stolen";9 in and of itself, that is a damning admission. Theft requires ownership -- which, in turn, demands authenticity. And if Bob had written Dead Air, that letter never would have been written. Accordingly, Bob did not write Dead Air.10 If the "Abbott letter" was the only evidence that Dead Air had been ghost-written, it would be quite persuasive; incriminating admissions made in a court proceeding, under penalty of perjury, are presumed to be true. But if you add it to the laundry list of corroborating evidence -- such as time sheets, internal memos, and rough drafts -- it becomes compelling. If you know where to look, this corroborating evidence can be found in the most amusing places. For example, in the Ministry's 1992 Form 990 -- which Larson signed under penalty of perjury -- Larson claimed to have worked a herculean 80 hours per week in his capacity as president of the Ministry.11 As a rule, novels take time to write, and because Bob was working so tirelessly on behalf of his Ministry, he obviously didn't have enough time left in his day to write Abaddon. B. Misrepresentation of the Ministry's Financial Condition When I personally confronted Bob Larson about the charges against him two years ago, he openly compared himself to Jesus, claiming that he was falsely accused, and being persecuted. But in the Gospel tale of Jesus' first trial, others offered false testimony; by stark contrast, the most incriminating evidence against Larson is his own public statements. He wrote to followers claiming that the ministry had suffered a $213,000 deficit in 1990,12 with constructive knowledge that BLM enjoyed a profit of over $500,000 for the year.13 His acts speak for themselves. But Larson doesn't appear to be content with merely misrepresenting the 'big picture'; his deceptive day-to-day fundraising practices are fast becoming the stuff of comedic legend. This Christmas season, in an apparent effort to increase flagging donations, Larson embarked on a plan to give money to needy callers in time for Christmas. But the woman who supposedly inspired the campaign called him on December 22; she hadn't received the aid as promised, and Bob had to tell her that 'the check was in the mail'.14 The very next caller advised Bob that she made a $500 "Champion" commitment "45 minutes ago" -- even though Bob complained a mere five minutes beforehand that he hadn't received one.15 Her call is further evidence that Larson routinely delays the acknowledgement of large gifts, thereby creating the false impression that the day's receipts are far less than they actually are.16 C. Bob Larson's Compensation from the Ministry The claim that Larson is shamelessly profiteering from his Ministry is supported by equally compelling evidence. The cornerstone of that evidence is his own financial affidavit, signed under penalty of per jury, in connection with his 1991 divorce. Yet, even though Ministry general counsel Chris Johnson admitted that the affidavit was authentic,17 and Fred Wheeler provided me with my copy, both Larson and his underlings have had the audacity to accuse me of fabricating it.18 The only reason Larson could even think of getting away with such a diabolical stunt is that he managed (in February of 1992) to have his divorce file sealed.19 I recently filed a successful motion to have the sealing order vacated;20 now I can prove, once and for all, that he is lying about me yet again. To the world, Bob has claimed that his divorce was a painful one, but a former Larson confidant assures me that it was he who inflicted most of the pain.21 Bob was the one who filed -- after ex-wife Kathy accused him of adultery.22 And when Bob gave her the divorce papers, Kathy "cried & accused [him] of not having Bible principles & character."23 For Larson, the only painful aspect of that divorce was that he had to give 58.5% of their $1.4 million marital estate to ex-wife Kathy, and pay her $3,700 per month in alimony.24 Indeed, he was so distraught over the break that, less than 48 hours after the divorce was finalized, he was sunning himself in Orlando with galpal Margo Hamilton.25 D. And His Apparent Sexual Escapades In the earlier stages of the Larson investigation, I tried to avoid looking at allegations that Bob was a serial adulterer, focusing primarily on his financial faux pas. But as the Bakker/PTL and Swaggart scandals taught us, whenever a media minister abuses the power of the pulpit, sexual misconduct almost invariably follows. Evidence from Bob Larson's diary suggests strongly that he was, in fact, unfaithful to his wife, even prior to his filing for a divorce. On January 7, 1991, Bob wrote that he had a "major confrontation w/ L over where she stands."26 On the 28th, there seemed to be cause for celebration; it was the "first time in 3 mo [he made] progress with L."27 But the next day was, in his words, one of the "worst days of life, L & I [are] apart again."28 Evidently, the relationship cooled. On July 11, 1991, Bob observed that "things improved with L but all personal is gone"29; thus it is clear that Bob was referring to a personal relationship. And on the 14th, he remarked that it was "strange to be back @ the hotel where 9 mo ago I came w/ L"30; thus it appears that he did a little personal traveling with her. "L" is almost certainly World magazine's star whistle-blower, Lori Boespflug. Bob is known to have traveled with her to Disney World in November of 1990, and he has, at times, acted very much the part of a jealous and obsessed lover.31 But at any rate, we know that "L" was not ex-wife Kathy; she is consistently referred to as "KL" or Kate." To me, the most illuminating aspect of the Larson diary is in what it says about other Christian leaders. For instance, it is reported that, in late 1990 and early 1991, Thomas Nelson president Sam Moore received two unsigned letters from BLM employees that asserted, among other things, that Larson had "had other adulterous encounters."32 According to the diary, Moore purportedly told Bob that "even if let ter was true he believed in what I did."33 In other words, Sam Moore could care less if Bob Larson was a panderer, a philanderer, or just a good old-fashioned fraud -- as long as Bob's books sold, Sam was a happy man. Moore's studied indifference to personal failings speaks volumes about the modern Christian business ethic (sort-of makes one respect Michael English). The evidence showing that Bob Larson has been raiding his ministry is absolutely compelling. The fact that he has used Ministry airtime to promote his books and novels is beyond dispute, and the fact that he has countersued me for allegedly interfering with a contract with one of his sponsors is an open confession that the time used had substantial commercial value. When I asked him about it two years ago, Bob admitted that he sold books to the Ministry.34 And every other component of my estimate of Bob's $400-500K compensation package can be traced to self-authenticating documents -- of which I have copies. Larson cannot dispute my allegations; all he can do is attack me personally. II. And the Lawsuit: Until this point, I have chosen not to draw attention to this law suit -- discussing it only when specifically asked to by journalists. But now, due in large part to Bob Larson's highly abusive and exorbitantly expensive campaign of legal harassment, it has become a story in and of itself. Thus, I have decided to go public with the purpose of (1) exposing Larson's shameless acts and (2) making a public offer that should give the BLM Board some incentive to adopt a more ethical course of action. A. Larson's Campaign of Legal Harassment Larson supporters have asked why Bob has not sued me for libel; the obvious answer is that he can't. He would do it in a heartbeat if he could -- but even he knows that it would be futile. Everything I say about him is documented to the hilt, and he knows it. Bob Larson has gone to extravagant lengths in his attempt to harass and intimidate me. The Ministry filed a countersuit, claiming that I had threatened to "boycott" one of Bob's sponsors -- Sears, Roebuck & Co. On the strength of an affidavit by IBN advertising agent Michael Davis, it is alleged that I called up Target and Response, a Chicago-based ad agency claiming that I was the leader of a group of "several hundred people" who were going to boycott all Sears products if they did not stop advertising on Bob's programs.35 Let's put this in perspective: In essence, Bob is suing me for what Rev. Don Wildmon does for a living! Wildmon can claim the allegiance of several hundred thousand people -- and he still gets doors slammed in his face. Bottom line, if I had been so foolish as to pull such a preposterous and utterly pointless stunt, the Sears Tower would have shaken ... with laughter! I did call Target and Response, but only for the legitimate purpose of conducting informal discovery related to the lawsuit. And perhaps it was 'divine providence', but I decided to tape the conversation in question. And as you will notice by listening to it (and a follow-up conversation with the person who purportedly relayed the information regarding the alleged "boycott" to Michael Davis), I didn't even mention Larson's array of ethical indiscretions. The reason is obvious: I didn't want to alienate the guy. It is frankly difficult to imagine how my conversation with Target and Response could have been transmuted into a "boycott threat." One regrettably plausible explanation for the discrepancy is that Larson attorney James Rollin Miller suborned Mr. Davis' perjury -- by adding the 'magic words' to his affidavit to justify a fraudulent allegation of tort liability. At the very least, Mr. Miller's refusal to with draw the counterclaim, given the existence of the tape, appears to be a flagrant breach of legal ethics. (Unfortunately, the legal profession has as many 'bad apples', per capita, as does the world of televangelism, and is almost as reluctant to police its' own.) Larson's brand of no-holds-barred, scorched-earth harassing litiga tion does not come cheap. During 1992, the Ministry spent more than $167,000 in legal fees, nearly 4% of its' annual revenue. The Ministry has 'officially' spent $107,000 in the defense of this lawsuit as of September 14;36 and that bill continues to mount at a rate of $3-6,000 per week. And just recently, he added Newport Beach-based psychiatrist Park Deitz -- who bills a Robert Shapiro-esque $600 per hour -- to his team. No wonder he needs Heroes. I have made several offers to settle this case, or in the alterna tive, take it to binding arbitration, but so far, Larson has refused to even entertain the possibility. Bob is willing to spend hundreds of thousands of dollars' worth of sacrificially-given money -- simply because the words, "I'm sorry," just aren't in his vocabulary. And who cares? After all, it's only God's money.... B. What It Tells Us About His "Ministry" The most tragic part of this whole affair is that those people who Bob Larson should have been accountable to have, by and large, over looked his many transgressions. Thomas Nelson has known for at least two years that "Bob's" novels were ghost-written -- and, according to one internal BLM memo, Nelson even furnished him with a work-for-hire contract.37 Various owners and managers of Christian radio stations have followed suit, the only notable exception being Salem Broadcast ing Co. president Ed Atsinger.38 The person responsible for Bob's "ministerial credentials," J. David Ford of Dave Ford's Evangelistic Messengers, was absolutely outraged when we brought these matters to his attention. And when Fred Wheeler contacted "Lifeline" (one of Bob's corporate sponsors, which markets itself as a Christian, "values-based" long-distance company), the reaction of company president Carl Thompson -- captured on voice-mail for posterity -- was, to put it politely, unique.39 But by far the most scandalous failure of stewardship is that of BLM's Board of Directors -- Dr. Jerry Prevo of Anchorage, Alaska, Dr. Terry Smith of Richardson, Texas, and retired Rev. Ross Johnston of Clearbrook, British Columbia. The BLM Board has consistently turned a blind eye to Larson's lavish appropriation of sacrificially-given resources, whether it be for first-class plane tickets, expensive hotel suites, free radio advertising time, or the use of salaried Ministry employees to ghost-write "his" books. And it didn't bother them that, even though the Minis try had roughly $1.7 million in cash reserves and an accumulated surplus of over $2 million, Bob was publicly claiming that the Ministry was on the ragged edge of financial disaster. As far as the Board is concerned, Bob can do no wrong. The latest instance of the BLM Board's scandalous neglect of their stewardship obligation occurred in this lawsuit. Several counts were dismissed, and with them, Bob Larson Ministries' legal obligation had effectively disappeared. Still, rather than do what they should have done -- move to be dismissed from the case -- they asked me to stipulate to the fact that Bob Larson was "acting within the scope of his employment" when he defamed me during the KNSS and WFTL interviews. Even though Bob Larson appeared on those interviews to, in his own words, "talk about my novel,"40 and the Ministry does not benefit in any material way from the sale of Bob's novels, the Ministry insisted upon accepting legal liability for his libelous statements. As near as I can tell, they were under no legal or moral obligation to do so; indeed, they had a stewardship obligation to the contrary. C. And What I Intend To Do About It Unlike the BLM Board, I am philosophically opposed to the wasteful misuse of little old ladies' Social Security checks. I am appalled by the way the BLM Board has squandered God's money in an attempt to salve Bob Larson's wounded ego, and have decided to do what I can to put a stop to it. Accordingly, I publicly make this following offer to settle my dispute with the Ministry: I hereby agree to release Defendants Bob Larson Ministries and International Broadcasting Network from this lawsuit for: (1) a public apology; (2) the withdrawal of their counter claims; (3) the promise not to indemnify Bob Larson for any further costs or legal fees he incurs in relation to this suit, and (4) cooperation with my requests for discoverable information in the Ministry's possession. I have previously made this offer privately, and now, I do so pub licly. It shall remain open until the close of business on January 3, 1994. [Please notice that I am not offering to settle my dispute with Bob Larson; all I am saying is that I consider it to be a flagrant breach of fiduciary duty for the Board to enable Bob Larson to misappropriate sacrificially-given Ministry funds in order to finance his own bloodthirsty private vendetta.] The most amusing part of this whole saga is the incredible ferocity with which Larson has pursued me. It is as if he thinks that if I go away, all would be right with his world. However, as I have repeated over and over, Ken Smith doesn't make these allegations ... THE DOCUMENTS DO! The evidence is there for all to see. Bob Larson intends to destroy me -- his $160,000+ legal bill41 is a stark testimony to his obsession. Whether he succeeds will of course be problematic; I am sorely out-manned and out-gunned (representing myself, out of sheer necessity), but remain committed to fighting the good and honorable fight. But I do not seek his destruction; rather, I desire his restoration (as do others who are working with me). If Bob would repent of his sins, recant his false statements, and reimburse those he has injured in his obsessively self-indulgent quest to become a religious tycoon, I will support him. We may disagree theologically, but a laborer who genuinely seeks to help others is always worthy of his hire. Bob Larson has been angry at me ever since the Westword article was published -- according to former BLM vice-president Boespflug, he was plotting his revenge nearly two and one-half years ago.42 And while I have, at times, been admittedly angered by Bob's vengeful response, this is not, and never has been, a vendetta against him. I have said it before, and will say it again: If he can show that anything I have written of consequence concerning him in any of my articles was materially in error, I will publicly retract it, and document the reasons for my retraction. _____________________________________________________________________ ENDNOTES 1Bob Larson Ministries, "'Talk-Back With Bob Larson' Stations" (memo), 5 Jun. 1992, p. 8 (chronology of the investigation courtesy Fred Wheeler). 2Michael Roberts, "The Evil That Men Do," Westword, May 27-Jun 2, 1992, p. 10 (hereinafter, "Westword"). 3Bob Larson, Memorandum (to Angelo Diasparra), 28 Dec. 1992, p. 1 (copy courtesy Jon Trott; read over the air in its entirety in School of Debate, note 5, infra.). 4Larson is believed to have used the pseudonym "JP Gallagher." Under that nom de plume, he revealed strikingly accurate information about me and those close to me that was not revealed to anyone else on the Prodigy service (e.g., the fact that my wife is a pharmacist). More over, JP revealed information about Larson that even members of his staff should not have known (e.g., the volume of advance sales for Abaddon -- which I was able to confirm covertly through sources at Thomas Nelson). As time wore on, and I continued baiting him, Bob finally let his 'cover' slip -- finally giving an accurate first-person rendition of a confrontation he had with former KKLA talk-show host John Stewart (except, of course, who won). 5See, "The Bob Larson School of Debate" (an excerpted compilation of interviews held on radio stations KNSS and WFTL on 15 Jul. 1993, and other Talk-Back broadcasts -- track 1 of enclosed tape; hereinafter, "School of Debate"). 6Ibid., ibid. 7Bob Larson, "Talk-Back With Bob Larson" (radio broadcast), 2 Nov. 1994; report confirmed by author in conversation with KTUU news desk on 7 Nov. 1994. 8William T. Abbott, Jr., Letter (to Bob Larson), July 8, 1991. (The letter was authenticated in court in Bob Larson Ministries v. Boesp flug, No. 93 CV 422 (Jefferson County (Colo.) Dist. Ct., filed 4 Mar. 1993, Complaint, p. 3; it was reproduced in Jon Trott, "Bob Larson's Ministry Comes Under Scrutiny," Cornerstone, Vol. 21, Issue 100, Feb. 1993, p. 41.) 9Bob Larson, "Talk-Back With Bob Larson" (radio broadcast), 28 Jul. 1993. 10The Larson diary lends tacit support to Lori Boespflug's claim that she was the primary author of Dead Air, while Larson assumed more of an editorial role. The evidence suggests that while Larson initiated the project, he lost interest, and delegated the project to Boespflug and Muriel Olson. See Ken Smith, "Sex, Lies, and Audiotape," avail able on Internet. 11Bob Larson Ministries, 1992 Form 990, Schedule I. 12Bob Larson, "Save A Day of Talk-Back On Your Station" (letter to donors), 4 Feb. 1991, p. 2. 13Bob Larson Ministries, 1990 Stewardship Report, undated, unpaged (listing total revenue of $5,613,445 and expenses of $5,103,648.) 14"Talk-Back With Bob Larson" (radio broadcast), 22 Dec. 1994. 15Ibid., ibid. 16Other examples of Larson's litany of fundraising misrepresentations can be found at Ken Smith, "The Cowering Inferno," pp. 7-11 and "Sex, Lies, and Audiotape," pp. 15-17, available on Internet. 17Westword, p. 12. 18E.g., School of Debate, note 5, supra. 19Larson v. Larson, No. 91 DR 226 (Jefferson County (Colo.) Dist. Ct., Court's Order Re Sealing of File, order entered 13 Feb. 1992. 20Ibid., Order entered 9 Dec. 1994. 21Lori Boespflug, interview with author, 16 Jun. 1992. 22Bob Larson, Diary (in manuscript), entry for 19 Jan. 1991 (edits in entries, where necessary for coherence, are denoted by brackets). 23Ibid., entry for 24 Jan. 1991. 24Larson v. Larson, Findings, Conclusions, and Order (and the Court's supplement thereto), entered 19 Sep. 1991. 25Bob Larson, Diary, entry for 14 Jul. 1991. 26Ibid., entry for 7 Jan. 1991. 27Ibid., entry for 28 Jan. 1991. 28Ibid., entry for 29 Jan. 1991. 29Ibid., entry for 11 Jul. 1991. 30Ibid., entry for 14 Jul. 1991. 31E.g., Lori Boespflug, "Employment Contract" (signed and dated by Larson), 29 May 1991, p. 1, note #6 (Larson made her stop seeing "the man who installed [her] carpeting"). Larson's apparently obsessive infatuation with Boespflug is further suggested by the fact that he named his child "Brynne Anne" -- hauntingly similar to the names of Lori's first two, Brenna and Rheanne. The link is further suggested by the fact that Larson claimed on one of his radio broadcasts that "Brynne" meant "defender of the faith"; those baby books I have consulted were unanimous in indicating that it is a feminization of the Welsh "Bryn" -- which means "hill." 32Salem Letter #1, p. 7, copy attached (Salem Letter #2 is referred to in Bob Larson, Diary, entry for Jan. 4, 1991). 33Bob Larson, Diary, entry for 27 Jan. 1991. 34Bob Larson, Interview with author, 17 Oct. 1992 (see also, Bob Larson Ministries, 1991 Consolidated Financial Statements, p. 8 (note 6). 35Smith v. Bob Larson Ministries, No. 94 CV 121 (Jefferson County (Colo.) Dist. Ct., filed 21 Jan. 1994), Affidavit of Michael Davis, pp. 1-2. But see track 2 of enclosed tape. 36Id., Ministry Defendants' Disclosure Certificate, p. 6. 37Bob Larson, Memo (to "Bonnie"), 3 Jul. [1992], p. 1. 38See, Bob Larson, Diary, entry for 27 Jan. 1991. 39"Talk-Back With Bob Larson" (radio broadcast), date unknown; Carl Thompson, Voice-mail message (to Fred Wheeler), 27 Sept. 1994 (copied by the author from voice-mail with permission of Fred Wheeler); track 3 of enclosed tape. 40School of Debate, note 5, supra. 41Our best estimate, based on the amount of work performed. 42Lori Boespflug, Interview with author. (The most sublime irony of this affair is that I had absolutely nothing to do with the Westword article; it's almost a pity that I can't take the credit for it.) ________________________________________________________________ Copyright 1994 Kenneth L. Smith. All rights reserved. Copying is permitted for non-commercial use only. Please direct your inquiries to the author at P.O. Box 280305, Lakewood, CO 80228 (journalists can fax me at (303) 670-8777). ================================================================ Follow-Up: (Posted Feb. 19, 1995) Note: In the past two years, much has been written - by secular and Christian sources alike - about the activities and practices of talkshow host Bob Larson, and questions surrounding Bob Larson Ministries. Rather than respond to inquiries in an open, Christlike manner, Mr. Larson tends to attack those who question him, going as far as making derogatory statements on the air. One of his favorite targets is Ken Smith, who has tenaciously researched and documented the allegations against Larson. As the above article shows, Ken Smith recently sued Larson for libel. However, a simple fact about this country's legal system is that the one with the most money has a distinct advantage over the one who does not have the luxury of deep pockets. The following letter shows, in essence, what a quarter-million dollars can purchase. We received, from an anonymous source, a copy of a letter sent to Mr. John Stewart, of the Law Offices of John Stewart, in Orange, California. John Stewart represents Ken Smith in his libel suit against Bob Larson. The letter, which by virtue of it having been filed in connection with a motion in the suit is in the public domain, was written by James R. Miller of Hopper and Kanouff, in Denver, Colorado. This is the content of said letter: --- Start Of Letter -------------------------------------------- VIA FACSIMILE (714) 283-7111 John Stewart, Esq. LAW OFFICES OF JOHN STEWART 1122 East Lincoln Avenue, Suite 203 Orange, California 92665 Re: Smith v. BLM, et al. Dear Mr. Stewart: Please accept this correspondence pursuant to C.R.E. 408. The settlement which you proposed on behalf of your client, Mr. Ken Smith, to Paul Wood, Esq. on December 1, 1994 is not acceptable to my clients. Our Supplemental Disclosure Certificates and expert reports are due on Monday, December 19, 1994. At that time, your client will formally become aware that we have retained as testifying experts in this matter Park Elliott Dietz, M.D., M.P.H., Ph.D. and Daniel A. Martell, Ph.D. These well-known doctors are two of the country's experts on stalkers and stalking behavior. They are expected to render their opinions, _inter alia_, that the Plaintiff is a stalker and that it was reasonable for the Defendants to label the Plaintiff as a stalker. Their opinions will be contained either in ther Supplemental Disclosure Certificate or the expert reports. Their opinions, coupled with the total lack of actual damages in this case, prompt the following settlement offer. The Defendant will accept the following in settlement of this case: 1. A letter signed by the Plaintiff for distribution to the public which states that the following statements made by the Plaintiff have, after further investigation, turned out to be totally untrue: a. That Bob Larson Ministries and Bob Larson solicit funds when the funds are not needed; b. That Bob Larson Ministries is guilty of criminal activity; c. That Bob Larson engaged in activities in his personal life which were inappropriate for a minister; d. That Bob Larson is not the author of the books that bear his name; and e. That Bob Larson is a liar. 2. The claims of all parties must be dismissed, with prejudice, each party to pay their own costs and attorney's fees. This would include the Ministry's counterclaims. 3. The settlement would be global. 4. An order that the parties return all discovery materials produced to each other and that the Court file be sealed. 5. Full and complete mutual releases would be executed. (These releases would cover the activities of the parties from the beginning of time to present.) 6. Neither party shall pay to the other monetary consideration. Please consider this an offer of settlement pursuant to the terms and conditions of C.R.S.  13-17-202 Very Truly Yours, HOPPER AND KANOUFF, P.C. (Signed) James R. Miller --- End Of Letter ---------------------------------------------- Ken Smith has never hidden the fact that he is an unbeliever. Some may question his actions or motivations, but with regard to his statements about Bob Larson and Bob Larson Ministries he does have the support of a number of highly-respected Christians. I encourage you to pray for Ken. Should you wish to contact him, you can do so by writing to: Ken Smith P.O. Box 280305 Lakewood, CO 80228 (Journalists can fax Ken at (303) 670-8777). or by leaving an email to Ken Smith, on Christian BBS Abba II: 619-487-6391/7746 ================================================================= þ About Christian BBS Abba II ================================================================= This file passed through Christian BBS Abba II. Abba II is a place where Christians find Fellowship, Information and Resources, and where non-Christians can find honest, intelligent answers about what (and why) Christians believe. We specialize in providing high-quality Christian files and programs. Call the BBS at 619-487-7746/6391 (up to 14,400 baud), =================================================================