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1 of Worldwide and its two related entities, defendants Ambassador
2 College, Inc. ("Ambassador"), and Ambassador International Cultura
3 Foundation, Inc. ("AICF
11
)1 together with Worldwide, Ambassador and
4 AICF will collectively be referred to herein as •the Church."
5
3. The Church, which was originally known as the Radio
6 Church of God, was founded by me in the mid-1930's for the purpose
7 of proclaiming "the Gospel throughout the world as a witness of
8 the coming of the Kingdom of God." Matthew 24:14. I am the
9 appointed Apostle of the Lord Jesus Christ and, as such, have been
10 both the spiritual and temporal leader of the Church from its
11 inception. In the more than 40 years since I founded the Church,
12 �he Church has grown and flourished to the point where it now has
13 approximately 100,000 members worldwide as well as countless
14 "co-workers," all of whom.donate funds to further the mission and
15 purpose of the Church and to support the many activities in which
16 it is engaged on a worldwide scale.
17
4. On January 3, 1979, I was advised by Mr.
c.
Wayne Cole,
18 a minister and Director of Pastoral Administration over the Church
19 ministry worldwide, that the California State Attorney General's
20
Office had initiated an investigation pursuant to which it had
21 attemp�,a, that morning, to invade the Church's executive offices
22 in PalQena., California on the pretext of examining the Church's
/:,_c_.,;. ..�_-,.,.
23 booka�:.. records in an attempt to obtain evidence of financial
24 improprieties on the part of myself, my personal adviser Stanley
25 R. Rader, and others. Although I was astonished beyond belief
26 by this bald governmental intervention in the Church's private
27 financial affairs with its equally clear impingement on the right
28 to religious freedom, I was not, and am not, afraid of an inspectio