MOLINTAIN OF FIRE AND MIRACLES rN TF{E

MiNISTRTES
(A Nevada Non-Profit Corporation) CIRCI.IIT COLIRT

c/o: Gilbert A. Garcia FOR

5861 Pine Avenue, Suite B
Chino Hills, Califomia 91709 PRINCE GEORGE'S COLNry
Axd CASE NO.: CAI16-26s32

MOLNTAJN OF FiRE AND MiRACLES,

INTERNATlONAT
A Religious Association

c/o: Gilbert A. Garcia

5861 Pine Avenue, Suite B
Chino Hills, Califo mia 9 17 09

Plahtiffs

CHRIST TT{E TRUTH MINISTRIES, TNC. *

5506 Church Road
Bowie, Maryland 20720 ' +

SERVE ON: ,r

Kayode Ojewale, Resident Agent

9520 Georgian Way *
Owings Mills, Maryland 21117

And

MOIINTAIN OF FIRE A\ID MIRACLES

MhIISTRIES MARYLAND,
INCORPORATED
(A Maryland Religious Corporation)
5506 Church Road
Bowie, Maryland 20720

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

COMPLAI}VT FOR DECLARATORY RELIET

AND FOR DAMAGES

.Plaintift and Petitioners, MolrNTAsi oF FIRE AND MIRACLES MINISTRES

 USA, b{C. and MOLINTAIN OF FIRE AND MIRACLES MINISTRiES, by its Atorneys,

FrRcusoN, Scurreltcu & Baltrw, P.A., Thomas J. Scheteiich and Rafiq R Gharbi, bring

this action compiaining against CHRIST THE TRUTH MINISTRES, INC., MOLNTAiN

OF FiRE AND MIRACLES MINISTzuES MARYLAND, INC. and LAWRENCE

oLUKtlt\Mi ADETLNTI, KAYODE OJEWALE, ELERA Nwocu, EMILOLA oKE,

KOFFI POSSIAN, MIRTAM A. MORGA}{, QUADRI ADELEKE, RAYMOND

AwosIKA, BEATRICE M. BOATENG, CHRISTOPFIER o. AKINDITRO, ISRAEL o.

ADETtiNJi, RONKE O. ADETTINJI and ESTHER A. ADETL\rJI.

This }egal action is for declaratory relief, compensatory damages, punitive

damages, and equitable reiief.

GENERAL ALLEGATIONS

1. MOLNTAIN OF FIRE & MIRACLES MIMSTRIES ("MOFMM,

DITERNATiONAL") is an i:rternational association of churches originally established in

Nigeria-

2. MOL]NTAIN OF FiRE AND MIRACLES MIMSTRiES, USA, INC.

(*MOFMM, usA") is a Nevada non-profir corporation created by MOFMM,

D'ITER.NATIONAL for the purposes of advancing the ministry of MOFMM,

INTERNATIONAL i:l the United States, holding assets for the use of the MOFMM,

INTERNATTONAL minislries in the United States. coordinating the legal financial

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

themselves with MOFMM, INTERNATIONAL.

 3. MOLINTAIN OF FIRE AND MIRACLES MIMSTRIES, MARYLAND,

INC- (*MOFMM, MARYLAND") is a Maryland religious corporation originally formed

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

Ministries, Maryland, lnc."

4" MOFMM, INTERNATIONAI is a hierarchical religious denomination. Its

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

to personai saving faith in tbe Lord.

5. MOFA,[N,{, INTERNATIONAL, of which MOFNOyI, MARYLAND was a

pafi" has a cent'ai governing body that acted regularly withia its powers. MOFMM,

INTERNATIONAL is directed by a General Overseer who is Dr. D.K. Olukoya. The

ministry is directed through a series of Regional Overseers, who oversee the local churches.

6- MOFIvft{, MARYLAND took title to property known as 5506 Church

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.

7. MOFMM, MARYLAND took title to the real propeffy known as 5503

Church Road Bowie, Maryiand by deed dated September 29,2004. This properry consists

of 1.3 acres (more or iess) on which is constructed a singie family home.

8. MOFV04, MARYLAND since its formation h35 sssrrmulated substantial

tangible personal properly including building fumishings, supplies, books, records,

 vehicles, home and office equipmenl appliances, equipment for use in the
ministry, and

other tangible personal property.

9' MOFlv04, N'{ARYLAND since its formatioq has acquired substantial

intangible properfy including bank accounts and investn:ent accounts.

10. All of the real property. tangible personal properqv, and intangif,le personal

property, held by MOFMM, MARYLAND was held in rrust for MOFMM,

D'ITERNATIONAL and specifically for the beneficia-y MoF\dM, usA.

11. The terrns of the tru$ were established by the docrtments of MOFMM,

hITERNATIONAL, and accepted by MOFMM, MARYLAND as detailed in the

aliegations foUowing.

12. It'2002, General Overseer Olukoya distributed a written direction from the

lntemational Headquarters of MOFMM, INTERNATIONAL, requiring local pastors to

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

OLUKLTNMi ADETT.INJI, Defendang was the Pastor of MOFlvOr4, MARYLAND and

subscribed and swore to the statement on October ZB,Z0A2.

13. on November 8, 2002, LAWRENCE ADETUNJI signed a Generai

Agreement inciuding that he would "ho1d this church in trust for and on behalf of Mountain

of Fire & Miracles Ministries."

14. on october 27, z0lz, MOFMM, USA issued a letter of appoinhent to

Pastor LAWRENCE ADETLNII, appointing him as Pastor of Bowie, Maryiaad Branch of

 MOFIO{, INTERNATIONAI. Purst,ant to the terms of the appointuenl LAWRENCE

ADETLD{JI would be responsible to his Regional overseer and to General

overseer

Olukoya-

15' The appointment required LAWRENCE ADETLNJI to strictly adhere

to

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,

including without limitation, credit reports or memorand4 reports of transactions

made on

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

the original book or record."

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

ADETLINJI under oatb in which he affirmed his loyalry to MOFIyL\4, INTERNATiONAL

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

for and on behalf of Mountain of Fire and Miracles Ministries u.s.A.,,

i8. The appoinhnent ietter signed by LAWRENCE ADETI-INJI stated rhat

"should I decide to withdraw as a pastor 6f \4euntain of Fire and

Miracles Minisfies, I

shall give the General Overseer and the Regional Coorriinator a min.imum
of thirfy (30)
days'notice of my intent to withdrawal.,,

19. on March 8,2014, MOFMM, MARYLAND amended its By-laws to stare

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

and Miracles Ministries, Maryland lnc. a Maryland non-profit Colporation

is hereby held

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

of Fire and Miracies Ministnes, lnc. a Nevada non-profit corporation.,,

21. The sarne amended By-laws srated that "Mountain of Fire and Miracles

Ministries, Maryland lnc., a Maryland non-profit Corporation hereby recognizes and

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

Miracles Ministries, Inc., 5 Nevada non-profit Corporation. it is further known 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

of Mountain of Fire and Miracles Ministries lnternational,,.

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."

23. The same Restated Articles of Lncorporation contained an Article Six,

which stated that the "real or personal assets, and money are held in trust for the benefit of

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

Ministries lnc., a Nevada Colporation."

24. The same Restated Articles of lncorporation contained an Article Seven

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

and Miracles Ministries lgc., a Nevada non-profit corporation.,,

25. The same Restated Articies of lncorporation required that certail actions

must be pre-approved rn writing by MoFMlv{, }.{TERNATIONAI before they can

 become effective: Amending or Restating the Articies of Incorporation; Amending,

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.

27. In 2015, Defendants LAWRENCE ADETL){JI, KAyoDE OIEWAIE,

ELERA NWOGU, EMILOLA OKE. KOFFi POSSIAN, }dM.IAM A. MORGAN,

QUADRi ADELEKE, &A.YMOND AWOSIKA" BEATRICE M, BOATENG,

CI*.ISTOPHER o. AKi].IDux.o. iSRAEL o. ADETLNJI. RONKE o. ADETLNTI, and

ESTHER A. ADETLTNJI agreed between them to deprive MOFh/n4, DITERNATIONAL

and MOFIv[kI, LrSA of thek interest in the reai properfy, tangible personal property, and

intangible personal properfy belonging to MOFMM, MARYLAND, to transfsl the same

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,

MARYLAND, MOFMM, INiTERNATIONAL, and MOF}yIN4, USA of the assets held in

trust for them.

28. On or about DecemberlS, 2015, in firrtherance of their conspiracy,

Defendants OJEWALE, .AKINDLIRO, NWOGU, OK_E, POSSIAN, MORGAN,

ADELEKE, AWOSIK,\ and BOATENG, being Trustees of MOFMM, MARYLAND,

executed Articles of Amendment and Restatement of MOFMM, MARYLAND. The

purpose of these amendments was to eliminate the obiigation of MOFMM, MARYLAND

and its Trustees to hold the reai properry, Angible personai property, and intangible

10
 personal property of the religious corporation in tnrst for the benefit of MOFIvIVI,

INTERNATIONAI and MOFIr4lr,I, USA.

29. On December 18, 2015, n fi.rrherance of their conspiracy, Defendant

LAWRENCE ADETUITIJI filed the December, 2A15 Articies of Amendment and

Restatement with the Maryiand State Departrnent of Assessments and Taxation.

30. The December, 2015 Articles of Amendment and Restatement were not

approved by nor submitted for approvai to MOFMM, D{TERNATIONAL or MOFMM,

USA, and were concealed from them by these Defendants.

31. The December, 2015 Articles of Amendment and Restatement were not

approved by nor submitted for approval to the congregation of MOFMM, MARYLANID,

and were concealed from it by these Defendants.

32- The December, 2015 Articles of Amendment and Restatement were

ineffective to revoke the trust established for the benefit of MOFMM, II{TERNATIONAL

and MOFMM, USA.

33. On January 4, 2016, in furtherance of 1fog qsnspiracy, Defendants

LAWRENCE ADETU\iJI, CHRISTOPFDR AXINDURO, ISRAEL ADETT"II{JI,

RONKE ADETLNI and ESTIIER ADETLNJI fi"led Articles of lncorporation for a

reiigious corporation known as GHRIST TT-IE TRUTH MIMSTRIES, Djc. These

Defendants named themselves as the Trustees of CHRIST THE TRUrH MINISTRES,

tr\iC.

34. on January 4, 2016, in furtherance of the conspkacy, cHRIST TFIE

TRUTI{ MINISTRiES registered the tradename "calvary House,'Bowie,, with the

11
 Maryland Departnent of Assessments and Taxation"

35. On Sunday, March 27,2016, in firtherance of the conspiracy and in breach

of his duties of trust, Defendant LAWREI{CE ADETTINJI announced to &e cgngregation

of MOFMM, MARYLAND that the church would no longer be parr of MoFMM,

iNTERIIATIONAL but would now be an independent church under the narne CHRIST

TT{E TRUTH MIMSTzuES.

36- On March 27, 2076, in furtherance of the conspiracy, the individual

Defendzrnts had the church signs bearing the name "Mountain of Fire Mirristries" removed

or changed to "Christ the Truth Ministries.,,

37. on March 28, 2a76, in furtherance of the conspiracy, Defendant

LAWRENCE ADETLTNJI fi-led a kadename applicarion for which he claimed personal

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

MOFIvS{, USA despite demand.

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

of the rights of MOFI,0,{, USA and MOFMM, bITERNATIONAL, without compensation

to these Piaintiffs.

42. The tangible personal property of MOFIvOvt, IvLARYLAND has never been

discributed by its Trustees to MOFMIvI, USA despite demand.

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

Defendants, in violation of the rights of MOFMM, usA and MOFMM,

hTTERNATIONAL, without compensation to those plaintifts.

44. The intangible personal propsrry of MoFIrd\,{, MARfLAND has never

been accounted for, or diskibuted to MOFMM, usA, despite the demand.

45. The intangible personal property of MOFIT4M, MARYLAND was taken by

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

46. The ailegations of Paragraphs 1 through 45 of this Complaint and Petition

are incorporated as if restated herein.

47. This action 15 sysrght purswmt to Maryiand Code, courts and Judicial

Proceedings Article, Title Three, subtitle Four, for Declaratory Judgment.

48. MOFMM, hITERNATIONAL and MOFMM, USA have an interest in the

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

or denied by the Defendant CIRIST THE TRUTH MhTISTzuES concerning ownership

and possession ofthe real properfy, tangible personal propeffy, intangible personal properry

that is titled to MOFI\,04, MARYLAND.

50. The real properry, tangible personal properry, and intaagible personal

property of MOFMM, MARYLAND should be d.istributed to MOFMM, USA to or

for the

benefit of MOFIv&,L INTERNATIONAL.

WHEREFOR-E, Plaintiffs/Petitioners pray tbat rhis Courr:

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

properry belongiag to MoFlr4li4, N(aRYLAND be and is the properry of MOFMM, USA

for the benefit of MOFlvftl, II\ITERNATiONAL;

B. Order the costs of this proceeding, and legai fees incr.rred by Piaintiffs to

be paid by CHRIST TIIE TRUTH ML\-ISTRIES; and

C. Crrant such other relief as justice may require.

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

51. The zrllegations of Paragraphs I through 50 of this Compiai:rt and Petition

are incorporated as if restated herei:r.

14
 52. lhe real property, tangible personal property, and intangible personal
properfy titled in MOFMM, MARYLAND was heid in trust by Trustees, the Defendants

LAWRENCE ADETTNJI, KAYODE OIEWALE, CHRISTOPTMR AKINDTIRO,

ELERA NWOGU, EMIi,OLA OKT, KOFFI POSSTAN, MIRIAM MORGAN,

QUADzu
ADELEKE, RAYN4OND AWOSIKA, AND BEATR]CE BOATENG.

53. GBENGA ARONMOLATE of 5 i 03 Glenn Daie Woods Court, Glen:r Dale,

Maryland is an interested person in that he is also a tnrstee.

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,

tangible persona.i property, and iatangtble personal properfy shail be distributed to

MOFNA4, D{TER}{ATIONAL by and through MOFMM, USA.

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,

NTERNATiONAL and/or MOF}vIN4, USA.

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

properry and urtangiblepersonalpropeffy instead to CHRIST THE TRUTT{ MINISTRIES,

and have permitted CHRIST THE TRUTH MnIISTR-ES to make use ofthe realproperty.

WHEREFOR-E, PiaintiffslPetitioners pray rhar this Court:

A. Adjust decree, and declare that Defendants LAWRENCE ADETI-INJI,

KAYODE OJEWALE, CHRISTOPI{ER AKNTDURO, ELERA NTWOGU, EMILOLA

15
 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.

B. Grant aa accounting to Plaintiffs/Petitioners for the fi.rll amount of the assets

of MOFMM- MARYLAND or its trustees, and the damages susta.rned by

PlaintiffslPetitioners.

C- Grant PlaintiffslPetitioners judgment in excess of $75,000 against each .of

the individual Defendants narned in this Count, in such amount as may be shown by the

accounting prayed herein.

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

provisions of the trust.

E" Grant PlaintiffslPetitioners interes! oosts, and attorney fees incurred in

prosecuting this action for Breach of l'rust and Fiduciary Dufy.

F. Grant such other reiief as justice may require.

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

57- The allegations of Paragraphs 1 through 56 of this Complaint and Petition

are iacorporated as if restated herein.

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

Maryland Code, Corporations & Associations Article $3-41 1.

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.

WHEREFORE, PlaintiffslPetitioners pray that this Court:

A. Assume jurisdiction over the liquidation of MOFIvfM, MARYLAND,

pursuant to Maryland Code, Corporations & Associations Article $3-41 1.

B. Appoint a Receiver for the accounti::g, liquidation and disa'ibution of the

,
assets of MOFMM, MARYLAND.

C. Grant PlaintiffslPetitioners i:rteres! costs, and attomey fees incurred in

prosecuting this action.

D. Grant such other reiief as juSice may requre.

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

60. the allegations of Paragraphs 1 through 59 of this Compiaint and Petition

are incorporated as if restated herein.

61. The taking of'the tangible personal assets titied to MOFMM, MARYLAND,

by CFRJST TF{E TRUST MI\'ISTRIES and LAWRENCE ADETT'IIIJI, CFIzuSTOPFffi,R.

AJ(D{DURO, ISRAEL ADETT-II.{JI, RONKE ADETLI}'iil and EST}IER ADETLD{JI was

17
 intentional exercise of dominiea and conhol over tangible personal property belonging
to

PlaintiffslPetiti oners, and without permi ssion or j ustifi cation.

62. Defendants CHRIST THE TRUTH MD,IISTRTES and LAWRENCE

ADETLNJI, CHRIS TOPHER AKINIDI.]RO, ISRAEL ADETI]NII, RONIKE ADETI.INJ]

al]d ESTIIER ADETLINJI remain in possession and control of the ungible personal

properfy belonging to Plaintiffslpetitioiers.

63. 'fhe value of tle tangible personal property

converted is in excess of

$75,000.

WHEREFORE, Plaintiffs/?etitioners pray that rhis Courr

A. Grant them judgment against CHRIST THE TRUTH MNISTRIES and

LAWRENCE ADETINJL CHzuSTOPI{ER AK-biDLIRo, ISRAEL ADETLNJI,

RONKE ADETTNJI and ESTHER ADETLTNJI in excess of $75,000.

B. Grant PlaintiffslPetitioners interesl costs, and attorney fees incurred in

prosecuting this action.

C. Grant such other reiief as justice may require.

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

64. The allegations of Paragraphs 1 through 63 of this Complaint and petition

are incorporated as if restated herein.

65. The individual Defendants LAWRENCE ADETU|{I, CHRISTOPHER

18
 AKINDIJRO, KAYODE OJEWALE, ELELA NWOGU, EMILOLA OKE, KOFFI

POSSIAN, MIRIAM MORGAN, QUADRI ADELEKE, RAYT4OND AWOSIK,A.

BEATRICE BOATENG, ISRAEL ADETLTNJI, RONKE ADETLNJI aad ESTHER

ADETLTNJI agreed and acted in confederation for the purpose of depriving

PlaintitrslPetitioners of their interest in the real property, ta"gible personal property. and

intangibie personal property titled to MOFMM, MARYLAND.

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

use of one or more organizations controiled by these Defendants or by some of them.

67. The actions of these Defendants, and each of them, were knowing,

intentional, and malicious against the rights and interests of Plaintiffs/Petitioners.

WI{EREFORE, PiaintiffslPetitioners pray that this Court:

A. Grant tbem judgment agai:rst Defendants LAWRENCE ADETLNJI,

CHRISTOPHER AK]NDIJRO, KAYODE OIEWALE, ELERA NWOGU, EMILOLA

OKE, KOFFI POSSIANI, MIRIAM MORGAN, QUADzu ADELEKE, RAYMO}trD

AWOSIKA, BEATRICE BOATENG; iSRAEL ADETT]}IJI, RONKE ADETTNJI ANd

ESTHER ADETLjNJI each in excess of $75,000 compensatory damages.

B" Grant them judgment against Defendants i-AWRENCE ADETLT{JI,

CHRISTOPI{ER AKSIDLS,O, KAYODE OJEWALE, ELERA NWOGU, EMILOLA

OKE, KOFFI POSSIAN, MIRIAM MORGAN, QUADzu ADELEKE, RAYMOND

AWOSIKA, BEATRICE BOATENG, ISRAEL ADETLTNN, RONKE ADETT,I}TIJI and

19
 ESTHER ADETINJI for punitive damages in ttre arnount of $250,000 each.

C. Grant Plaintiffs/Petitioners interes! costs, and attorney fees incurred in

prosecuting this action.

D. Grant such other reiief as justice may require.

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

68. The allegations of Paragraphs 1 through 67 of this Complaint and Petition

are incorporated as if restated herein.

69. The individual Defbndants LAwRENCE ADETLTNI, cHRISTopFmR

AKbIDLIRO, KAYODE OIEWALE, ELERA NWOGU, EMiLOLA OKE, KOFFI

POSSLdN, I\4iRtAM MORGAN, QUADzu ADELEKE, RAYMOND AWOSIKA

BEA'TRICE BOATENG. ISRAEL ADETLNJI, RONKE ADETII.{JI and ESTHER

ADETUNI, acting in concer! failed to advise MoLl.lrArN oF FIRE \,INISTRES,

II{TERNATI0NAL, MOFMM, USA or the congregation of MOFMM, MARyLAND of

their actions detailed in this Complaint and Petition.

70. The individual Defendants had a duty as fiduciaries anci by express

agreemnt to disclose the actions detaiied in this Complaint and Petition to MOFMM,

IN{TERI.JATiONAT, MOFMM, USA and the congregation of MoF}vo4, MARYLAND.

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.

WHEREFORE, Plaintiffs8etitioners pray that this Court:

A' Grant them judgment against Defendants LAWRENCE ADETIINJi,

CHRISTOPHER AKNDLRO, KAYoDE OJEWALE, ELERA Nwocu, EMiLOLA

OKE, KOFFI POSSIAN, T,flRIAM MORGAN, QUADRI ADELEKE, RAYMOND

AWOSIKA" BEATzuCE BOATENG, ISRAEL ADET1iNJI, RoNKE ADETUNJI and

ESTHER ADETLNJI each in excess of $75,000 compensatory damages.

B. Grant them judgmenr again5l Defendants LAWRENCE ADETLNJI,

CHRISTOPT{ER AKINDURO, KAYODE OJEWAIE, ELERA NWOGU, EMILOLA

OKE, KOFFI POSSIAN, MIRIAM MORGAN, QUADRI ADELEKE, RAYMOND

AWOSIKA, BEATRICE BOATENG, ISRAEL ADETI-]NJI, RONKE ADET'INJI ANd

ESTHER.ADETLNJI for punitive darnages in rhe amount of $250,000 each.

C. Grant PlaintiffsPetitioners interesl costs, and attomey fees incurred in

prosecuting this action.

D. Grant such other reiief as justice may require.

COTIIYT SE\EN
F'RAUD
AGAINS T DEFEI\'DANT LAWREN CE ADETTINJI

73. 'Ihe allegations of Paragraphs 1 through 72 of this Complaint and Petition

are incorporated as if restated herein.

74. The representations made by Defendant LAWRENCE ADETUNJI to

Plaintiffs were false when made; and to the extent they were promises of future

perforrnance he had no intention of compiying with when made.

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 75. Defendant LAWRENCE ADETTNJI knew that the representations were

untrue when he made them to PiaintiffslPetitioners.

76. Defendant LAWRENCE ADETL]NJI made the representations for the

purpose of defrauding Plaintiffs/Petitioners.

77. Plarntiffs/Petitioners relied with justification on the representations of

Defendant LAWRENCE ADETLNI.

78. Piaintiffs/Petitioners have sustained damage as a direct result of their

reliance on the unkue allegations of Defendant LAWRENCE ADETT.INJI.

WHEREFORE, Plaintiffs/Petitioners pray that this Court:

A. Grant them judgment agains Defendant LAWRENCE ADETLNJI, in

excess of $75,000 compensatory damages.

B. Grant them judgment against Defendant LAWRENCE ADETIINJI for

punitive da:nage i:r the amount of $250,000.

C. Grant PlaintiffslPetitioners interes! costs, ald attorney fees incurred in

prosecuting this action.

D. Grant such other relief as justice may requ:re.

COTNT EIGHT
EJECTMENT
AGAI}{ST DEFENDANTS CHRIST TIIE TRUTH MINISTRIES
AND LAWRENCE ADET{.]NJI

79. The allegations of Paragraphs 1 through 78 of this Complaint and Petition

are incorporated as if restated herein.

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,

22
 Bowie, Maryland.

8 1- Defendant LAWRENCE ADETLTNJI has remaiaed in possession of the real

properfy known as 5503 Church Road and 5506 Church Road, Bowie, Maryland, without

right to do so.

82- Piaintiffsfetitioners are entitled to immediate possession of the properties

at 5503 and 5506 Church Road, Bowie, Maryland.

83. As a result of the wrongful possession of CHRIST TI{E TRUTH

MII\iISTRIES and LAWRENCE ADETLINJI, Plaintiffs,Petitioners have suffered

economic loss, in the loss of use of the properties.

WHEREFORE, PlaintiffslPetirioners pray that this Courr:

A. Grant them judgment againsr Defendants CHRIST THE TRUTH

MhTISTRIES and LAWRENCE ADETLNI. in excess of $75,000 compensatory

damages.

B' Grant PlaintiffslPetitioners interest, costs, and attomey fees incurred in

prosecuting tbrs action.

C. Grant such other relief as justice may require.

ZJ
 Respectfuily submitted,

FL.lttGUSoN, ScurrEt.tcti & Briilew, p.A.

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