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1
COMPLAINT
Pamela Koslyn (State Bar #120605)
LAW OFFICES OF PAMELA KOSLYN
6255 Sunset Blvd., Suite 716
Hollywood, California 90028
Telephone: (323) 467-2200 Fax: (323) 648-8222
Email: pkoslyn@koslynlaw.com
Attorneys for PLAINTIFFS
FREEDOM FROM RELIGION FOUNDATION,
& DR. SARI DWORKIN
Superior Court of California
County of San Luis Obispo
FREEDOM FROM RELIGION
FOUNDATION, a Wisconsin corporation;
and DR. SARI DWORKIN, an individual,
Plaintiffs,
v.
CITY OF PISMO BEACH, a municipal
corporation; PISMO BEACH CITY
COUNCIL, the governing body of the CITY
OF PISMO BEACH; SHELLY
HIGGINBOTHAM, an individual in her
capacity of Pismo Beach Mayor; and PAUL
JONES, an individual in his capacity as
Pismo Beach City Chaplain; and DOES 1-
100, inclusive,
Defendants.
Case No.
PLAINTIFFS COMPLAINT FOR
CONSTITUTIONAL AND CIVIL CODE
VIOLATIONS SEEKING
DECLARATORY RELIEF,
INJUNCTIVE RELIEF, AND NOMINAL
DAMAGES
INTRODUCTION
1. The Pismo Beach City Council (Council) begins each of its bi-monthly
meetings with an official Christian prayer. All but one of the 126 prayers given from January 1,
2008, through October 15, 2013, were addressed to the Christian god, and all were directed at
Pismo Beachs citizens. Christian clergymen delivered 123 of the 126 prayers: the City Chaplain,
a Pentecostal clergyman, gave 112 prayers and other Christian clergymen gave 11 more. See
Exhibit 1, pp. 1-135, copies of transcripts of those prayers.
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COMPLAINT
2. The prayers advance and proselytize for Christianity. They distort and
fabricate American history to further the appearance that our government endorses and supports
Christianity, and they disparage non-Christians by claiming that not living in accordance with the
Christian gods rule of law is sinful and wrong.
3. The City established a Christian Chaplaincy and appointed Defendant Paul
Jones (Chaplain Jones) to that position eight years ago. When Chaplain Jones gives the
prayers, he repeatedly cites the Christian bible and, with the imprimatur of a government office,
declares that it is divinely authored. Since Jones was appointed City Chaplain, he has led the
Pledge of Allegiance at the City Council meetings immediately after the prayers even if he does
not give the prayers (see, e.g., Exhibit 1 at p. 134). Jones not only Christianizes United States
history, but he exhorts Pismo Beach citizens to elect righteous leaders, and instructs those
leaders to govern according to his gods bible. This chaplaincy is a government office with solely
religious functions, and this City Chaplain receives benefits at public expense.
4. The Council has publicly endorsed, and aligned itself with, a single
religion, Christianity, by establishing this chaplaincy and sponsoring sectarian prayers that
proselytize and advance Christianity, and disparage non-Christians. These prayers signal to non-
Christians that they are outsiders at Council meetings, are unrepresented in their government,
and are not full citizens.
5. Plaintiffs seek a declaration that the prayers are unconstitutional, a
permanent injunction against the prayers, and a declaration that the appointment of a City
Chaplain is unconstitutional. Plaintiffs seek nominal damages, attorneys fees and costs.
JURISDICTION AND VENUE
6. This action arises under Article I, 4; Article XVI, 5; Article XX, 3 of
the California Constitution; and Cal. Civ. Code 52.1 (b).
7. This Court has jurisdiction pursuant to California Code of Civil Procedure,
394, 410.10.
8. This Court is the proper venue pursuant to California Code of Civil
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3
COMPLAINT
Procedure 395.
PARTIES
9. Plaintiff Freedom From Religion Foundation (FFRF) is a national
non-profit Internal Revenue Code 501(c)(3) educational charity and a Wisconsin non-stock
corporation. FFRF defends the constitutional separation between state and church, and educates
the public about the views of non-theists. FFRF has nearly 20,000 members nationwide,
including more than 2,800 members in California. FFRF represents and advocates on behalf of
its members throughout the United States.
10. Plaintiff Sari Dworkin (Dworkin) is a citizen and taxpayer of Pismo
Beach and has resided there since 2000. Dworkin earned a Ph.D. (University of Nebraska,
Lincoln) and also holds M.S. and B.A. degrees (Herbert H. Lehman College, NYC). She taught
graduate level courses at the California State University, Fresno, and is now retired from
teaching but still practices as a licensed psychologist. Dr. Dworkin is a member of Atheists
United of San Luis Obispo (AUSLO), FFRF and the Congregation Beth David a reform
Jewish congregation in San Luis Obispo. Dr. Dworkin identifies as an atheist Jew, and she
objects to the Pismo Beach City Councils prayers. Dr. Dworkin has attended several Pismo
Beach City Council meetings over the last 6 years, in conjunction with her involvement in land
development issues in Pismo Beach, such as those involving Mike Hodges, 1 Price Canyon, and
Spanish Springs, and has watched meetings online and read transcripts of meetings as well. All
the meetings she attended, viewed, participated in, or read transcripts of, opened with sectarian
prayer. Dr. Dworkin was very surprised at those prayers, which she interpreted as addressed to
the Christian God, to a Christian City Council as a religious body, and to only Christian citizens
and Christian interests. She feels it unbelievable that such invocations exist in a country that
separates church and state. She is still very interested in Pismo Beach land development issues,
and intends to attend and view and read transcripts of the meetings in the future. The prayers
cause her to feel offended, disenfranchised, and intimidated about participating in her own
government. While protesting these prayers at the public council meeting, Dr. Dworkin is forced
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4
COMPLAINT
by the Councils procedures to give her name and address, but after they had ignored her
concerns , she felt vulnerable and uncomfortable, and had trepidation about attending any further
meetings. Similarly, as a member of AUSLO, Dr. Dworkin often hosts parties at her home, and
her affiliation with AUSLO as well as her name and home address are publicized in conjunction
with these parties, so the City Councils deliberate disregard for her atheism by continuing with
its City Council meetings prayers and Christian chaplaincy, has made her feel ostracized and
even physically unsafe.
11. Other concerned citizens of the area who support Plaintiffs arguments in
this case include among others, David Leidner, Kurt Horner, Dorothy Ellis, Steve Arkowitz,
Paul Rinzler, Kim McGrew, Cesar Reyes, Terrence Jones, Laura Montecalvo, and Martin
Williams, as well as journalists including among others Colin Rigley (see
http://www.newtimesslo.com/commentary/8207/repent/ and Matt Fountain (see
http://www.newtimesslo.com/news/7997/pismo-panned-over-public-prayers/.
12. Defendant City of Pismo Beach (City or Pismo Beach) is a municipal
corporation in the County of San Luis Obispo, California, subject to the jurisdiction and venue of
this Court. Pismo Beach is a general law city, vested with the power to make and enforce
within its limits all local ordinances and regulations not in conflict with general laws. The City
has less than four square miles of land and a population of less than 8,000.
13. Defendant City of Pismo Beach City Council (Council) is responsible for
governing the City. The Council has five members and a mayor who serve part time and
meet twice a month. The Council typically deals in local issues such as permitting, zoning,
licensing, land use and development, public works, and tourism.
14. The Council appointed Paul Jones the City Chaplain (Jones) in 2005, and
it grants Jones a privileged opportunity to pray at every meeting. The Council has officially
honored Jones for his years of ordained service. See Exhibit 2.
15. Defendant Shelly Higginbotham (Mayor Higginbotham) is Mayor of
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5
COMPLAINT
the City of Pismo Beach and has held that position since November 2010. Mayor Higginbotham
officiates at Council meetings and introduces the City Chaplain or substitute prayer-giver.
Mayor Higginbotham is being sued in her official capacity.
16. Defendant Paul Jones is the City Chaplain of Pismo Beach. Jones is being
sued in his official capacity. Jones has delivered nearly 90% of the invocations since January
2008. According to the Proclamation of the City Council of the City of Pismo Beach honoring
Jones for 60 years of ordained service, Jones is a leader in the International Church of the
Foursquare Gospel, a Pentecostal sect of Christianity. Jones graduated from a bible school
affiliated with the Foursquare Pentecostal sect, acted as pastor in various Foursquare Pentecostal
churches, and is a bishop for that sect. See Exhibit 2. The International Church of the
Foursquare Gospel affirms the inspiration and authority of scripture, the trinity, and other
orthodox Protestant evangelical doctrines and tenets, and emphasizes the baptism of the holy
spirit and speaking in tongues.
17. The fictitiously named Defendants sued as DOES 1 through 100,
inclusive, and each of them, were in some manner responsible or legally liable for the actions,
events, transactions and circumstances alleged herein. The true names and capacities of such
fictitiously named Defendants, whether individual, corporate, associate or otherwise, are
presently unknown to Plaintiffs and Plaintiffs will seek leave of Court to amend this Complaint to
assert the true names and capacities of such fictitiously named Defendants when the same have
been ascertained. For convenience, each reference to a Defendant will also refer to the Doe
Defendants.
18. Defendants were the agents, employees, partners, joint-venturers, co-
conspirators, owners, principals, and/or employers of the remaining Defendants, and are, and at
all times alleged herein were, acting within the course and scope of that agency, partnership,
employment, conspiracy, ownership and/or joint venture, and the acts and conduct alleged herein
of each Defendant were known to, authorized by, and/or ratified by the other Defendants.
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6
COMPLAINT
FACTS
19. Official city business is conducted at the Pismo Beach City Council
meetings, which meetings are held on public property located at 760 Mattie Road, Pismo Beach,
California, 93449. These meetings are held in a relatively small room. Each public speaker,
including Plaintiff Dworkin, is required to fill out a blue card with her or his name and address on
it, and to recite their name and address before speaking for their allotted three minutes. The
invocation is included on the meeting agenda, and official minutes are posted online, and for
many years, the meetings have also been televised and recorded for online viewing. The room is
too small to exit or not ones head in prayer without everyone noticing, and the City is so small
that it is typical for people to know one another personally or through another Pismo Beach
acquaintance. At the beginning of every meeting after the call to order and taking of attendance
of the government officials, Mayor Higginbotham, in her official capacity, asks all attendees,
including Council members, government employees, citizens, and students, regardless of their
religious beliefs or lack thereof, to rise for the invocation. These invocations, which are included
on each official meeting agenda, are directed at the Council as well as at the citizens attending
the meetings and those watching online. Non-Christians wishing to participate in their
government are forced to endure this invariably Christian religious ritual at every meeting.
20. Pismo Beach citizens have opposed including sectarian prayers at City
Council meetings since at least 2003. See Exhibit 7, p. 2. In fact, the official minutes do not
reflect the substance of the public comment, but it is possible that one or both the speakers who
voiced support for, and opposition to, the resolution prohibiting sectarian invocations wanted to
ban all Council meeting invocations altogether because such invocations were unnecessary
and/or offensive to nonthesists. At any rate, at least one of these two speakers, David Taub,
went to this meeting specifically to support a prohibition on sectarian prayers at Pismo Beach
City Council meetings.
21. Moreover, at the March 1, 2005, Council meeting, one of the two citizens
who made public comments on the prayers and proposed chaplaincy opposed this chaplaincy.
See Exhibit 4, p. 3. At that meeting, the Council acknowledged the legal difficulties with a
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COMPLAINT
chaplaincy, admitting that sectarian invocations are improper at a City Council meeting. The
council continued:
If the effect of establishing a City Chaplain position would be to
preclude other ministers from giving an invocation, then the City is
assuming some undetermined legal risk. Further, since the City has no
historical chaplaincy program, instituting such a program may have
significant constitutional obstacles especially in Californias litigious
climate.
See Exhibit 3, p. 5.
22. Nonetheless, the Council established the City Chaplain position, appointed
Jones to the post, and authorized the purchase of business cards and an official nametag. See
Exhibit 4 at p. 3, Exhibit 9.
23. Opposition to the chaplaincy and prayers continued, and in May 2012,
AUSLO sent a letter to the Council objecting to the prayers. See Exhibit 5. AUSLO did not
receive a response.
24. In followup to that AUSLO complaint letter, on June 5, 2012, Plaintiff
Dworkin, a member of both FFRF and AUSLO, objected to the prayers during the public
comment at the Council meeting. Defendant Mayor Higginbotham cut off her objections after
three minutes. AUSLO member Kurt Horner also went on record with a public comment at that
Council meeting and brought the Council a copy of his May 15, 2012, letter sent via e-mail. He
offered to take questions about the legal rationale for opposition to the Councils prayers, but the
Council had no questions, and did not respond in any way to Ms. Dworkin or Mr. Horner either
at that meeting or thereafter.
25. Plaintiff FFRF wrote a letter to the Council on August 15, 2012, repeating
the objections to the prayers and elaborating on the legal authority calling for their termination.
See Exhibit 6. FFRF did not receive a response.
26. Not only has the Council ignored these complaints and attempts to follow
up on these complaints, but it has never complied with or enforced the policy it adopted on
August 5, 2003 and re-affirmed on March 1, 2005, prohibiting offering sectarian prayer. See
Exhibit 3, p. 5, 10; Exhibit 7, p. 2.
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COMPLAINT
27. Public school students attend and speak at City Council meetings. See e.g.,
Exhibit 8, pp. 1-6.
The Prayers Are Sectarian.
28. These sectarian prayers begin with a reference to the Christian god,
conclude with a reference to the Christian god, declare the Christian bible to be divinely
authored, and cite to it repeatedly.
29. Each prayer begins by invoking the Christian god. Of the 119 fully audible
prayers, 115 used Christian honorifics to address the Christian deity: 108 to Our Heavenly
Father, two to Our Father in Heaven, two to Our Father, one to God, Our Father, and
one to Our Eternal God, Our Father. Three more addressed Our Eternal God, which, like
Our Eternal God, Our Father, or Eternal God, Our Heavenly Father, is a Judeo-Christian
addressespecially when the Pentecostal clergyman concludes the prayer in the name of Our
Blessed Redeemer and Dearest Friend or in the name of Our Lord and Dearest Friend.
The Prayers Conclude in the Name of the Christian God.
30. Chaplain Jones or his substitute gave 122 prayers in the name of the
Christian Lord as follows:
67 prayers were given in the name of our personal Savior and Lord
33 were similar but with additional or varied Christian embellishment
five prayers were given in the name of Christ our Lord
one was given in his name as Your Son and Our Savior
six were given in the name of Christ the Redeemer (e.g., in the name of the great
Redeemer, Your Divine Son, June 1, 2010, prayer) or Christ, Jesus, Our Lord
(July 16, 2013, prayer)
nine were given in the name of the Lord with varying embellishment
one was given to great God Our King.
See Exhibit 1.
31. Often the invocations given in the name of the Christian god use a
combination of the aforementioned Christian phrases including: Him who Isaiah called the
Prince of Peace (twice), Redeemer or redemptive name (six times), Your Divine Son
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(once), Loving Lord (seven times), personal (79 times), Savior (90 times), personal
Savior (74 times), and Lord (111 times.) Examples of these combinations include:
... in the blessed name of our Savior and Lord. May 6, 2008, prayer.
See Exhibit 1, p. 9.
in the name of Your Son and our Savior. May 19, 2009, prayer.
See Exhibit 1, p. 33.
through Christ our Lord. August 18, 2009, prayer.
See Exhibit 1, p. 40.
in the name of the great Redeemer, Your Divine Son. June 1, 2010, prayer.
See Exhibit 1, p. 58.
in the name of our gracious Redeemer and Lord. April 5, 2011, prayer.
See Exhibit 1, p. 75.
in the name of him who Isaiah called the Prince of Peace but
whom we know as our personal Savior and Lord, in His name we pray.
July 19, 2011, prayer.

See Exhibit 1, p. 82.
we pray this holy Christmas season in the name of Him who was
born in Bethlehems manger and who has become our personal Savior
and Lord. December 20, 2011, prayer.
See Exhibit 1, p. 91.
. . . in the blessed name in the wonderful name of our Savior and Lord.
June 4, 2013, prayer.
See Exhibit 1, p. 126.
through Jesus Christ our Lord. July 16, 2013, prayer.
See Exhibit 1, p. 130.
32. The prayers are addressed to our God 99% of the time (at least 118 times
of 119 full audio) and conclude in the name of our God 95% of the time (119 of 125 prayers).
Plaintiffs allege that the use of the word our, as in our personal Savior and Lord, in the
prayer context is not only sectarian, but also excludes them and all non-Christians. Plaintiffs
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10
COMPLAINT
allege that the use of the phrase our personal Savior and its variants are particularly sectarian
and exclusionary because only Christianity claims a personal savior.
The Chaplains Use of the Christian Bible in the Prayers is Sectarian.
33. City Chaplain Jones gives official government endorsement to the Christian
bible in two ways. First, he uses the prayers to give official sanction to sectarian beliefs found in
his religions bible. Second, he references, quotes, or cites that bible no less than 88 times.
34. City Chaplain Jones (or his substitute) used the phrase Holy Scripture 43
times (more than the phrase the Bible which was used 39 times) and attributes authorship of
the Christian bible (as if there was only one version of these books), to his God at least ten times.
He used the phrase Your Word seven times, Holy Scriptures of God, Your Book and the
Holy Writings of God once each.
35. Plaintiffs feel excluded when the government makes the claim that the
Christian bible is holy or that it is divinely authored. Such claims are sectarian, as would be
declaring that the Quran or the Book of Mormon was written by a god, or declaring
Mohammed a prophet, as Islam claims.
36. Plaintiffs feel excluded whenever the City Chaplain references, cites,
or quotes the Christian bible, and Jones has done so in referring to the book of Psalms at least 37
times, Proverbs at least 22 times, Isaiah at least 11 times, Timothy at least ten times, Luke at
least nine times, Matthew at least three times, and James at least three times.
37. The above statistics are not exhaustive because Holy Scripture is often
quoted without stating the source. For instance, Jones delivered a prayer with multiple
unattributed Christian bible quotes on December 15, 2009, when he officially proclaimed:
But the babe that was born in Bethlehems manger will yet remain
the babe that was born in Bethlehems manger will continue to bring
happiness and satisfaction. For His name is above all other names, His
reign is above all other rulers, and His truth is above all other.
See Exhibit 1, p. 48.
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The City Chaplain cites or quotes Psalm33:12, Blessed is the nation whose God is the Lord, at least 16 times. The
sectarian nature of the word Lord in the prayer context is evident is this passage. The City Chaplains repeated use of the
quote is meaningless if Lord refers to a generic, common god (Blessed is the nation whose God is God). The quote only
has meaning if Lord specifically invokes the Christian God (Blessed is the nation whose God is YHWH, the Christian
God). Lord is the name for a particular god, the Christian god Yahweh. In J udeo-Christian writings the name was rendered
as YHWH the tetragrammaton (Greek: Four Letters) was ineffable, so Lord was substituted. Thus, the passage is
sectarian, as are prayers given in the name of our Lord.

11
COMPLAINT
The two references to Jesus Christ as the babe born in Bethlehems manger, are from the
Christian bibles book of Luke 2:3 and 2:12; His name is above all other names is from
Philippians 2:9.
38. Examples of the City Chaplains use of the Bible in official government
prayers include:
The Scriptures teach us, saying, Blessed is the nation whose God
is the Lord.
1
We recognize that we are a nation under God. Our
forefathers have handed us the torch of faith; you alone have given us our
freedom, our liberty, and our prosperity. And faith in God is our heritage
and our foundation. It was President George Washington who reminded us
that morality and faith are the pillars of our republic. But it is evident that
these pillars are being eroded in our secular and permissive society. Too
long, we have neglected Your Word and ignored your laws. We have tried
to solve our problems without reference to You. Your word is so clear, and
is so simple. For Your Word says: righteousness exalts a nation, but sin is a
reproach and an embarrassment to any people. And so we confess to you
our sins, and ask that we as a nation and as individuals, may experience a
moral and a spiritual restoration. October 6, 2009, prayer.
See Exhibit 1, p. 43.
For it is recorded in Holy Scripture, and King Solomon declared it in 930
B.C., God is a shield to those who put their trust in Him. And again he
said, He who trust [sic] in the Lord shall prosper. And again he said,
Whoever trusts in the Lord shall be safe and secure. And his father before
him, King David wrote, He that trust [sic] in the Lord, mercy shall surround
him. Our forefathers read and reread these portions of Holy Scripture, and
anchored their faith and their future to them. March 2, 2010, prayer.
See Exhibit 1, p. 52.
It is clear that the Bible has had an incredible influence in shaping the history
of our great country, the United States of America. King Solomon wrote in
the Holy Scriptures, Blessed is the nation whose God is the Lord. And so
tonight, we seek your help, oh God, through daily prayer and daily Bible
reading that we may be able to guarantee for generations to come that we
remain one nation under God, indivisible, with liberty and justice for all, for
the more we absorb the Scriptures and seek to live by its precepts .
September 4, 2012, prayer.
See Exhibit 1, p. 106.
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Rices words are an introduction typical of the Christian Bible, specifically the writings attributed to Paul. Most of Pauls
letters include a greeting referencing God Our father. See Romans 1:7; 1 Corinthians 1:3; 2 Corinthians 1:2; Galatians 1:3;
Ephesians 1:2; Philippians 1:2; Colossians 1:2; 2 Thessalonians 1:1; 2 Thessalonians 2:16; Philemon 1:3. See also J ames :27.
[See Appendix of Out of State Authority]
12
COMPLAINT
Christian Clergymen Gave Almost Every Prayer.
39. Of the 126 invocations from 2008 through October 15, 2013, 99% of them
were Christian. Christian clergy delivered 98% (123 of 126) of the prayers. Defendant Jones,
the Pentecostal City Chaplain, gave 112 invocations; the Reverend Paul Toms, a pastor at the
Christian Evangelical Grace Bible Church, gave ten (several in the name of Christ, our Lord or
Christ Jesus Our Lord); and Father Victor Abegg, pastor at St. Paul the Apostle Catholic
Church, gave one. Rebecca McMurry, then-CEO of the Pismo Chamber of Commerce,
delivered one of the three prayers not delivered by Christian clergy, and it was strikingly similar
to Chaplain Jones prayers. See e.g. November 15, 2011, prayer, Exhibit 1 at p. 89. City
Manager Kevin Rice gave the other prayer. Both McMurrys and Rices prayers were Christian.
McMurry addressed the prayer to Our Heavenly Father, called for obedience to Holy
Scripture, asked the Council to make decisions that will honor You [God], and gave the
prayer in the name of our Lord. See February 3, 2009, prayer, Exhibit 1, p. 26. Rice invoked
the Christian deity, God our Father, creator of all.
2
See November 6, 2012, prayer, Exhibit 1,
p. 111. The sole non-Christian prayer-giver was Rajan Zed, a Hindu cleric from Reno, Nevada,
who gave the invocation on October 1, 2013, reading quotes from Hindu scripture and
addressing the Hindu God, thus making his prayer just as sectarian as the Christian prayers.
Jones Exploits the Prayers to Proselytize, Disparage non-Christians, and Advance
Christianity.
40. Virtually all of Jones prayers order citizens to live in accordance with his
gods laws, criticize citizens who do not do so, or lobby the Council to govern so as to honor his
god. For instance, in his prayer at a City Council meeting on April 6, 2010, City Chaplain Jones
lobbied:
The power of prayer is a dynamic force that repels unrighteousness, but
the influence of prayer has been dramatically reduced in our public life.
And the moral compass of the Holy Scriptures has been largely laid
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COMPLAINT
aside. Public morality is declining to dangerously low points. So help
each of us to always seek to live justly, and to pursue righteousness,
and to be zealous for a lifestyle that honors God. Give to them your
solution to every difficulty May proper decisions be made tonight
that will honor You.
See Exhibit 1, p. 54, emphasis added. Jones delivered nearly identical prayers on October 7,
2008 and on April 7, 2009. See Exhibit 1, pp. 19, 30. Further, on September 17, 2013, Jones
prayed:
Cause our leaders and our citizens to stand up for clear standards
expressed in the Bible, the Holy Writings of God. May they stand firm
for our freedoms to live by these standards. .. . Allow your Infinite
Wisdom to be graciously bestowed on our City Council whom we have
freely elected. May your leadership be manifested in their lives and in
their decisions as well as the staff that supports them. . . Fill City Hall
and these Council chambers with the peace and the power of your
eternal presence and cause every home and every citizen in Pismo
Beach to feel the impact.
See September 17, 2013, prayer, Exhibit 1, p. 133, emphasis added.
41. These prayers are official government admonishments to all citizens (each
of us, every home and every citizen in Pismo Beach) to be zealous for and live a lifestyle that
honors the Christian god, and to the Council to serve and honor the Christian god (and not all
gods of all of Pismo Beachs people).
42. Plaintiffs are disparaged by government claims that the moral compass of
the Holy Scriptures has been largely laid aside and that public morality is declining. April 6,
2010, prayer, see Exhibit 1, p. 54. Plaintiffs do not derive their morality from any bible, nor do
they conflate religion with morality. They are denigrated by government claims that one religion
has a monopoly on morality and, that therefore, nonadherents of that religion are immoral.
43. Other examples of official prayers that advance Christianity include:
May we never resist Gods will in our lives but, rather, may we value
godliness and pursue righteousness each day. For the Bible teaches us that
righteousness and right living are essential to a healthy society. May we seek
the Lord and obey the Bible, so as to walk daily in the purity of Gods ways.
Cause us to make godliness, as recorded in the Scripture, to be our lifes
standards. cause each of us, as individuals and as a nation, to repent of
our sins and turn wholeheartedly to honor You and to serve You. March
17, 2009, prayer.

See Exhibit 1, p. 29.
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14
COMPLAINT
In Deuteronomy chapter 30, verse 15, the Holy Scriptures record, See?
Ive set before you today life and good, death and evil, and that I command
you today to love the Lord your God, to walk in his ways, to keep his
commandments, his statutes, and his judgments that you may live and
multiply and the Lord your God will bless you in the land which you go to
possess. God is asking America to make the same choice today in order for
us to rebuild Americas crumbling moral foundation. God has made it clear
that he will continue to bless our land if we choose to love him and walk in
his ways. As a nation and as individuals, we can stand before almighty God
and say to him, we love you Lord, and as a people we will walk in your
ways and keep your commandments. March 6, 2012, prayer.
See Exhibit 1, p . 95.
King Solomon stated, The way of the Lord is strength for the upright
and he who walks in integrity walks securely. The righteous has an
everlasting foundation and will never be moved, and the memory of the
righteous is blessed. Many of our citizens and leaders have turned from the
path of righteousness in our lives and lifestyles. Infuse this ideal from King
Solomon once again into our public mind, and may it be practiced by our
citizens. October 16, 2012, prayer.
See Exhibit 1, p. 110.
44. Jones prayers affiliate the government he speaks for with the church he
also speaks for. These prayers additionally disparage and ostracize those who do not share City
Chaplain Jones faith in his god, or derive their moral code from his holy book:
Two weeks from today, November 4th, as United States citizens, we
will be electing a new president, a full House of Representatives, and
numerous senators. In our city of Pismo Beach, we will be electing our
city mayor, and two council members. Cause each of our citizens to
accept their responsibility and privilege to vote, and help us as
individual citizens to elect leaders whose lifestyles and judgements have
pursued integrity and righteousness. For King Solomon wrote in the
Holy Scriptures, Righteousness exalts a nation, but sin is a reproach to
any people. October 21, 2008, prayer.
See Exhibit 1, p. 20.
Ethics, morals, standards of behavior, these are determined by God rather
than majority of people. So tonight, enable each of us to stand firm for our
godly convictions, understanding it is an honor and a privilege to stand for
right. May the deep abiding sense of Gods holiness and Gods
righteousness always determine our sense of right and wrong. Tonight we
strongly affirm our nations motto; in God we trust. Help us to maintain
these and this firm conviction in our hearts and in our lifestyles. For only
then we will not be helpless or defenseless as we face the future. November
18, 2008, prayer.

See Exhibit 1, p. 21.
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See also, J ones nearly identical prayers on October 20, 2009, October 19, 2010, and February 7, 2012, Exhibit 1, at pp. 44,
66, and 93.
15
COMPLAINT
And God is always true to his character, as we seek his face and prayer and
respond to his holy promise in the Scriptures, it will change the way we
think and the way we behave. For sin and spiritual decline removes the
favor of God, but if we repent, God will forgive and pardon our sins, and
replace them with his righteousness in our lives. Each day we rest upon the
unfailing promise found in the Scriptures, Isaiah 41:10, Fear not for I am
with you. Be not dismayed, for I am your God. I will strengthen you, I will
help you, I will uphold you with my righteous right hand. May 5, 2009,
prayer.
See Exhibit 1, p. 32.
We ask that you will cause every citizen to perform their civic duty and
vote this season. Cause us to elect leaders who will stand up for the
clear standards that are expressed in the Bible, the Holy Writings of
God. October 16, 2012, prayer.
See Exhibit 1, p. 110.
City Chaplain Jones Revises and Christianizes History to Advance his Religion.
45. At least 54 of Jones prayers contain versions of history revised to misstate
and exaggerate the influence of Christianity on the founders and our countrys founding a
Christianized version of history.
46. Plaintiffs are excluded and disenfranchised by official governmental
proclamations that dishonestly Christianize United States history. Plaintiffs believe these
historical fabrications give the untrue appearance that Christianity is and has been the basis of the
United States government and is uniquely aligned with our government. This show of favoritism
is evident not only in the Chaplains privileged office and opportunity to give governmental
weight to the fabrications, but also in the fabrications themselves. Plaintiffs are marginalized and
disparaged because the Chaplain uses his governmental position and authority to co-opt
Americas greatness for Christianity and thereby advance that religion.
47. For instance, City Chaplain Jones claims include many unspecified
references to the founding fathers beliefs in God and the Bible, e.g., May 17, 2011, prayer, see
Exhibit 1, p. 79; August 19, 2008, prayer, see Exhibit 1, p. 16.
3
48. Jones also re-imagines history and the actions of the United States
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See also prayers on September 16, 2008, October 21, 2008, February 2, 2010, April 20, 2010, and Exhibit 1, pp. 18, 20, 50,
55.
5
Max Farand, The Records of the Federal Convention of 1787, Volume 1 (Yale University Press, 1911) p. 452, n. 15. Available
at the Library of Congress website:
http://memory.loc.gov/cgi-bin/query/r?ammem/hlaw:@field%28DOCID+@lit%28fr001136%29%29.

16
COMPLAINT
founders to show that his religion is the religion of this nation. For example, of Benjamin
Franklins prayer proposal at the Constitutional Convention, City Council Chaplain Jones
asserted, James Madison concurred and such resolution was passed . . . June 3, 2008, prayer.
See Exhibit 1, p. 11.
4
However, the prayer motion did not pass. The prayer motion was so
unimportant that the Constitutional Convention did not even bring it to a vote, let alone pass it.
Benjamin Franklin wrote of his own motion that The Convention, except three or four persons,
thought prayers unnecessary.
5

49. Jones has also said:
James Madison said, We have staked the whole future of American
civilization not upon the power of government, far from it, we have
staked the future upon the capacity of each and all of us to govern
ourselves according to the Ten Commandments of God. August 5,
2008.

See Exhibit 1, p. 15; see also March 2, 2010, and June 7, 2011, prayers, Exhibit 1, pp. 52, 80.
Our Heavenly Father, Thomas Jefferson in a prayer March 4, 1805, he
prayed, Almighty God, may we always prove ourselves to be a people
mindful of your favor and glad to do Your Will. Save us from violence, and
confusion, and pride, and arrogance, and from every evil way. Endow with
your spirit of wisdom, those we entrust with the authority of government,
that there may be justice and peace, and through obedience to your word,
we may show forth your praise among the nations of the world. God, who
gave us life, gave us liberty, can the liberties of a nation be thought secure
when we remove the conviction in the minds of people, that these liberties
are the gift of God? February 17, 2009, prayer.
See Exhibit 1, p. 27.
It was George Washington, our first president, who said, It is impossible to
rightly govern without God and the Bible. August 4, 2009, prayer.
See Exhibit 1, p. 39; see also, prayers on March 16, 2010, August 3, 2010, and September 18,
2012, Exhibit 1, pp. 53, 61, 108.
In 1787 at the Constitutional Convention, James Madison read from the
Bible, Isaiah 33:22, The Lord is our judge, the Lord is our lawgiver, the
Lord is our king; he will save us. And on the basis of the bible reading, he
proposed the plan to divide our central government into three branches:
judicial, God our judge; legislative, God our lawgiver; and executive, God
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In the same order:
Madison never said that American civilization is staked on the Ten Commandments or anything similar. See
Robert Alley, Public Education and the Public Good, William and Mary Bill of Rights Journal, Summer 1995,
pp. 316-318. Available at http://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1501&context=wmborj.
According to the Thomas Jefferson Foundation, which runs and maintains Jeffersons estate at Monticello, This
prayer was not written or delivered by Thomas Jefferson. It is in fact from the 1928 United States Book of
Common Prayer. See http://www.monticello.org/site/research-and-collections/national-prayer-peace.

Washington never said or wrote this. See Paul Boller and John H. George, They Never Said It: A Book of Fake
Quotes, Misquotes, and Misleading Attributions, 126-7 (Oxford University Press, 1989).
Madison did not read from the bible at the Constitutional Convention. Historians are certain that separation of
powers did not come from the bible. It came from Montesquieu who never mentioned or referred to the Bible in
his discussion of the separation. See Barron Charles Louis Joseph de Secondat Montesquieu The Spirit of the
Laws, Book XI. Madison devoted the Federalist no. 47 to the workings of this invaluable precept in the science of
politics and wrote that no political truth is certainly of greater intrinsic value, or is stamped with the authority
of more enlightened patrons of liberty, than that [of separation of powers.] He goes on to say [t]he oracle who is
always consulted and cited on this subject is the celebrated Montesquieu. Furthermore Isaiah 33:22 does not
separate power; it concentrates power in one being. The founders thought that concentrating these [powers] in
the same hands is precisely the definition of despotic government (Thomas Jefferson, Notes on the State of
Virginia, Query 13, 120-121, 1784) and that such a concentration was the very definition of tyranny. The
Federalist No. 47 (James Madison). Each of these three sources appears in The Founders' Constitution: Vol. I
Major Themes, 318, 319-320, 325-328, 623-628 (Philip B. Kurland, Ralph Lerner eds., Liberty Fund)(2000).
17
COMPLAINT
our king. He discovered our model of government from the eternal
governor. June 18, 2013, prayer.
See Exhibit 1, p. 127.
50. Each of these is a fabrication.
6
Plaintiffs feel excluded when the
government advances City Chaplain Jones religion by approving these sectarian fabrications and
claims that our government was founded on and is aligned solely with his religion.
51. As noted in the attached Exhibit 1, this Complaint does not contain an
exhaustive list of these revisions of history. Other historical fabrications in the prayers include
the idea that our founding fathers carved words of praise to god in nearly every building and
monument and memorial in our capital city (September 2, 2008, prayer, see Exhibit 1 , p.
17), despite the fact that most of those buildings do not include such representations and those
that the Chaplain cites were built in the 20
th
century; distortions about Congress printing bibles
and about the ministerial training of the signers of the Declaration of Independence (July 7, 2009,
prayer, see Exhibit 1, p. 36 ); and the whopper that the most frequently cited source in the
founding era of our great country was the Bible. September 4, 2012, prayer, see Exhibit 1,
p. 106.
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COMPLAINT
The City of Pismo Beach Gives Both Tangible and Intangible Aid to One Religion.
52. The City Council gives both tangible and intangible aid for sectarian
religious purposes, and in this tangible way, gives its Citys seal, literally, and its seal of approval,
figuratively, to Chaplain Jones. For two examples, the City Council purchased City Chaplain
Jones a nametag and authorized the purchase of business cards bearing the Pismo Beach official
seal. See Exhibit 4, p. 3, City Council Resolution #05-011; see also Exhibit 9.
53. The City Council lends the power and prestige of the government and
people of Pismo Beach to the Chaplains particular religious beliefs. The City accords this one
set of sectarian religious beliefs a privileged place at each government meeting and welcomes
that religions prayers at such meetings.
54. The City Council has established an official government office and title for
one particular religion, which happens to be the religion of the majority, thereby awarding it the
power and prestige of the government. Only one person, representing one religion, has ever
occupied the office. The Chaplain wields that prestige in recognition of that power: Tonight, in
the dignity of this public City Council meeting, we invoke your divine presence ... June 18,
2013 prayer (emphasis added). See Exhibit 1, p. 127; see also August 20, 2013 prayer, Exhibit
1, p. 131.
FIRST CAUSE OF ACTION
VIOLATION OF THE CALIFORNIA CONSTITUTION - PRAYERS
(Against All Defendants)
55. Paragraphs 1 through 54 of this Complaint are incorporated by reference as
if set forth in full.
56. These prayers are given under color of law, by the official City Chaplain,
fulfilling his duty as City Chaplain, with the full knowledge and permission of the City Council
that created the Chaplaincy, during official government meetings conducting city business. The
Council practice of sponsoring these prayers at meetings constitutes the custom and policy of the
City of Pismo Beach.
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COMPLAINT
57. These prayers serve no secular purpose, have the effect of endorsing one
particular sect, and entangle the government with religion. The prayers proselytize and advance
Christianity while disparaging non-Christians.
58. The fact that the City adopted a non-sectarian prayer policy eight years ago
is not a defense for the City because it is the City Councils custom and practice not to enforce
the policy, and instead to sponsor sectarian prayers at their meetings.
59. These prayers violate the California Constitutions No Preference and
Establishment Clauses, which guarantee free exercise and enjoyment of religion without
discrimination or preference, and which prohibit the legislature from making any law respecting
an establishment of religion.
60. Defendants have, under color of state statutes, ordinances, regulations,
policies, custom, and usage, deprived Plaintiffs of rights secured by the California Constitution,
entitling them to a remedy.
61. As alleged herein, an actual controversy has arisen and now exists between
Plaintiffs and Defendants. Plaintiffs contend that Defendants acts and omissions as pleaded,
including the prayers, violate the California Constitution. Plaintiffs expect Defendants to contend
that their acts and omissions do not violate the California Constitution. A judicial declaration
resolving these actual controversies between the parties is necessary and appropriate so the
parties may ascertain their respective rights, duties and obligations. Plaintiffs seek a judicial
determination that Defendants are violating California law, and further request permanent
injunctive relief.
SECOND CAUSE OF ACTION
VIOLATION OF THE CALIFORNIA CONSTITUTION - CHAPLAINCY
(Against All Defendants)
62. Paragraphs 1 through 54 of this Complaint are incorporated by reference as
if set forth in full.
63. The official appointment of a City Chaplain serves no secular purpose, and
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COMPLAINT
advances one religion over others and religion over non-religion. It also entangles the
government with religion, in among other ways, by Jones recitation of the Pledge of Allegiance
at each City Council meeting at which he leads prayers.
64. Jones uses his official position to proselytize for Christianity, advance that
sect, and disparage non-Christians.
65. The Council practice of sponsoring sectarian prayers at meetings constitutes
the custom and policy of the City of Pismo Beach.
66. Defendants have, under color of state statutes, ordinances, regulations,
policies, custom, and usage, deprived Plaintiffs of rights secured by the California Constitution.
67. As alleged herein, an actual controversy has arisen and now exists between
Plaintiffs and Defendants. Plaintiffs contend that Defendants acts and omissions as pleaded,
including the chaplaincy, violate the California Constitution. Plaintiffs expect Defendants to
contend that their acts and omissions do not violate the California Constitution. A judicial
declaration resolving these actual controversies between the parties is necessary and appropriate
so the parties may ascertain their respective rights, duties and obligations. Plaintiffs seek a
judicial determination that Defendants are violating California law, and further request permanent
injunctive relief.
THIRD CAUSE OF ACTION
VIOLATION OF THE CALIFORNIA CONSTITUTION - AID
(Against All Defendants)
68. Paragraphs 1 through 54 of this Complaint are incorporated by reference as
if set forth in full.
69. The appointment of a City Chaplain and the purchase of a name tag or
badge for the chaplain (and perhaps business cards as well) violate the no aid provision of the
California Constitution:
Neither the Legislature, nor any county, city and county, township,
school district, or other municipal corporation, shall ever make an
appropriation, or pay from any public fund whatever, or grant anything
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COMPLAINT
to or in aid of any religious sect, church, creed, or sectarian purpose, or
help to support or sustain any school, college, university, hospital, or
other institution controlled by any religious creed, church, or sectarian
denomination whatever; nor shall any grant or donation of personal
property or real estate ever be made by the state, or any city, city and
county, town, or other municipal corporation for any religious creed,
church, or sectarian purpose whatever .
See Cal. Const. art. XVI, 5.
70. No legitimate secular or government interest is served by appointing a City
Chaplain.
71. This aid is not available to secular and sectarian persons or institutions
equally; it is only available to the religious, and, in Pismo Beach, only available to Christians.
72. The prayers and chaplaincy impose a financial burden on the government
and taxpayer. It is not simple financial aid that article XVI 5 prohibits; it also prohibits all
forms of governmental aid to religion, whether tangible, such as cash, or in the intangible form
of prestige and power. It bans any official involvement which has the direct, immediate, and
substantial effect of promoting religious purposes. In Pismo Beach, both tangible and intangible
benefits are bestowed to a single sect with the establishment of the City Chaplaincy. These
special privileges to the Chaplain and to the religion he represents violate the California
Constitution.
73. As alleged herein, an actual controversy has arisen and now exists between
Plaintiffs and Defendants. Plaintiffs contend that Defendants acts and omissions as pleaded,
including the prayers, chaplaincy, and aid violate the California Constitution. Plaintiffs expect
Defendants to contend that their acts and omissions do not violate the California Constitution. A
judicial declaration resolving these actual controversies between the parties is necessary and
appropriate so the parties may ascertain their respective rights, duties and obligations. Plaintiffs
seek a judicial determination that Defendants are violating California law, and further request
permanent injunctive relief.
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COMPLAINT
FOURTH CAUSE OF ACTION
VIOLATION OF THE CALIFORNIA CONSTITUTION - CHAPLAINCY
(Against All Defendants)
74. Paragraphs 1 through 54 and 63 through 67 of this Complaint are
incorporated by reference as if set forth in full.
75. The Citys Chaplaincy violates Article XX, 3 of the California
Constitution. That provision lays out the oath and qualifications for any California public office.
The City Chaplaincy is a public officer and employee which includes every officer and
employee of the State, including the University of California, every county, city, city and county,
district, and authority, including any department, division, bureau, board, commission, agency, or
instrumentality of any of the foregoing.
76. After the secular oath, 3 reads: And no other oath, declaration, or test,
shall be required as a qualification for any public office or employment.
77. The City requires that a religious person with religious training serve as
City Chaplain.
78. No legitimate interest is served by the appointment of a City Chaplain.
Creating a public office and requiring that it be held by a religious person, as Defendants have
done, violates Article XX, 3 of the California Constitution.
79. As alleged herein, an actual controversy has arisen and now exists between
Plaintiffs and Defendants. Plaintiffs contend that Defendants acts and omissions as pleaded,
including the chaplaincy, violate the California Constitution. Plaintiffs expect Defendants to
contend that their acts and omissions do not violate the California Constitution. A judicial
declaration resolving these actual controversies between the parties is necessary and appropriate
so the parties may ascertain their respective rights, duties and obligations. Plaintiffs seek a
judicial determination that Defendants are violating California law, and further request permanent
injunctive relief.
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COMPLAINT
FIFTH CAUSE OF ACTION
VIOLATION OF THE CALIFORNIA CONSTITUTION AND THE CIVIL CODE -
COERCION OF CITIZENS
(Against All Defendants)
80. Paragraphs 1 through 54 of this Complaint are incorporated by reference as if
set forth in full.
81. California Civil Code (Civil Code) 52.1 authorizes a claim for relief
against anyone who interferes, or tries to do so, by threats, intimidation, or coercion, with an
individuals exercise or enjoyment of rights secured by federal or state law.
82. This includes claims against anyone who tries to force someone to do
something not required to be done under the law.
83. Defendants force Plaintiffs to undergo a Christian religious ritual in order to
exercise their constitutionally protected right to participate in and monitor their democratic
government and choose their own method and form of worship, including none at all.
84. Defendants are liable under the California Constitutions No Preference and
Establishment Clauses, and under Civil Code 52.1 for forcing and coercing Plaintiffs into
religious worship.
85. As alleged herein, an actual controversy has arisen and now exists between
Plaintiffs and Defendants. Plaintiffs contend that Defendants acts and omissions as pleaded,
violate the California Constitution and Civil Code. Plaintiffs expect Defendants to contend that
their acts and omissions do not violate the California Constitution and/or the Civil Code. A
judicial declaration resolving these actual controversies between the parties is necessary and
appropriate so the parties may ascertain their respective rights, duties and obligations. Plaintiffs
seek a judicial determination that Defendants are violating California law, and further request
permanent injunctive relief.
REQUEST FOR RELIEF
Plaintiffs seek judgment as follows:
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COMPLAINT
1. On the First Cause of Action, for a declaratory judgment that Defendants
prayers violate Article I, 4 of the California Constitution; for nominal damages for past
violations of constitutional rights; for a permanent injunction ordering Defendants to refrain from
prayers at government meetings; and for court costs and attorneys fees pursuant to California
Civil Procedure 1021.5, California Civil Code 52.1 (h), and pursuant to the substantial benefit
doctrine.
2. On the Second Cause of Action, for a declaratory judgment that Defendants
appointment of a City Chaplain and providing the Chaplain with items of monetary value and
intangible aid at the public expense violates Article I, 4 and Article XVI, 5 of the California
Constitution; for nominal damages for past violations of constitutional rights; for a permanent
injunction ordering Defendants to permanently dissolve the position of City Chaplain; and for
court costs and attorneys fees pursuant to California Civil Procedure 1021.5, California Civil
Code 52.1 (h), and pursuant to the substantial benefit doctrine.
3. On the Third Cause of Action, for a declaratory judgment that Defendants
aid given to prayers and to the City Chaplain violate Article XVI, 5 of the California
Constitution; for nominal damages for past violations of constitutional rights; for a permanent
injunction ordering Defendants to refrain from providing any tangible or intangible aid for
religious purposes, including without limitation prayers or an official chaplaincy; and for court
costs and attorneys fees pursuant to California Civil Procedure 1021.5, California Civil Code
52.1 (h), and pursuant to the substantial benefit doctrine.
4. On the Fourth Cause of Action, for a declaratory judgment that Defendants
appointment of a City Chaplain required to adhere to a religion or believe in a god to hold such
public office violates Article XX, 3 of the California Constitution; for nominal damages for past
violations of constitutional rights; for a permanent injunction ordering Defendants to permanently
dissolve the position of City Chaplain; and for court costs and attorneys fees pursuant to
California Civil Procedure 1021.5, California Civil Code 52.1 (h), and pursuant to the
substantial benefit doctrine.
5. On the Fifth Cause of Action, for a declaratory judgment that forcing
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COMPLAINT
plaintiffs to attend a Christian religious ritual in order to exercise their constitutionally protected
right to participate in their democratic government, and interfering with plaintiffs right to choose
their own method and form of worship, including none at all, violates the California Constitution
and Civil Code 52.1; for a permanent injunction ordering Defendants to refrain from prayers at
government meetings; and for court costs and attorneys fees pursuant to California Civil
Procedure 1021.5, California Civil Code 52.1 (h), and pursuant to the substantial benefit
doctrine.
6. On All Causes of Action, for such further and equitable relief as the Court
may deem appropriate.
Dated: November 1, 2013 LAW OFFICES OF PAMELA KOSLYN
By: __________________________________
PAMELA KOSLYN
Attorneys for PLAINTIFFS
FREEDOM FROM RELIGION FOUNDATION
DR. SARI DWORKIN
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Pamela Koslyn (State Bar #120605)
LAW OFFICES OF PAMELA KOSLYN
6255 Sunset Blvd., Suite 716
Hollywood, California 90028
Telephone: (323) 467-2200 Fax: (323) 648-8222
Email: pkoslyn@koslynlaw.com
Attorneys for PLAINTIFFS
FREEDOM FROM RELIGION FOUNDATION,
& DR. SARI DWORKIN
Superior Court of California
County of San Luis Obispo
FREEDOM FROM RELIGION
FOUNDATION, a Wisconsin corporation;
and DR. SARI DWORKIN, an individual,
Plaintiffs,
v.
CITY OF PISMO BEACH, a municipal
corporation; PISMO BEACH CITY
COUNCIL, the governing body of the CITY
OF PISMO BEACH; SHELLY
HIGGINBOTHAM, an individual in her
capacity of Pismo Beach Mayor; and PAUL
JONES, an individual in his capacity as
Pismo Beach City Chaplain; and DOES 1-
100, inclusive,
Defendants.
Case No.
PLAINTIFFS EXHIBITS
1
PLAINTIFFS' EXHIBITS
2
PLAINTIFFS EXHIBITS LIST
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Exhibit List
Exhibit 1 Transcripts of invocations given at Pismo Beach City Council meetings from 2008
through October 2013
Exhibit 2 Pismo Beach City Council proclamation to honor the City Chaplains years of
ordained service
Exhibit 3 Excerpt from March 1, 2005, Pismo Beach City Council Agenda explaining the legal
difficulties of the prayers and establishing a chaplaincy
Exhibit 4 Excerpt from March 1, 2005, Pismo Beach City Council Minutes including objections
to prayers and chaplains and the vote establishing the chaplaincy
Exhibit 5 Atheists United of San Luis Obispos May 15, 2012 letter to the Pismo Beach City
Council protesting the sectarian prayers and chaplaincy
Exhibit 6 FFRFs August 15, 2012 letter to the Pismo Beach City Council protesting the
sectarian prayers and chaplaincy
Exhibit 7 Excerpt from August 5, 2003 Pismo Beach City Council Minutes adopting a prayer
policy and the policy itself
Exhibit 8 Excerpts from Pismo Beach City Council Minutes where students attended the
meetings
Exhibit 9 Photographs of City Chaplain wearing his official city nametag with city seal and
giving invocations behind an overlay of the official city seal and text noting invocation
as an agenda item.
1
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
Transcripts of Invocations
Given at the Pismo Beach City Council 2008 - 2013
Unless otherwise indicated, the text below is the complete text of an invocation given by the City
Chaplain Dr. Paul Jones.
Where only partial text was available, or where a stand-in for Jones gave the invocation, this will be
indicated immediately after the date.
In every case, the mayor asks all attendees to stand during the invocation and remain standing while the
same invocation speaker also directs the Pledge of Allegiance.
1
This direction from the mayor usually
takes the form of:
The next item on our agenda is the invocation, which will be given by [Jones or his stand-in].
Please stand and remain standing for the Pledge.
In each instance, we endeavored to transcribe the prayers fairly and accurately. It is possible that
mistakes have been made. Footnotes were used to note biblical authority or historical inaccuracies and
are not part of the actual prayer.
1
In the single instance of a non-Christian giving a prayer, Rajan Zed was not permitted to say the Pledge of Allegiance.
The City Chaplain still handled that responsibility.
2
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
January 15, 2008
Will you please bow your heart with me in prayer? Our Heavenly Father, this is the first city council
meeting conducted this new year, 2008. And tonight, we reflect on the many ways that you have
blessed our great country and our beautiful city in 2007. Many good decisions have been made by our
city council, and you have blessed us with your presence, with your divine protection and with
prosperity. And tonight we say thank you for the many favors that you have given to us which we
enjoy. Thank you especially for our continued liberty and freedoms.
Our founding fathers have declared in our Declaration of Independence the immortal phrase: We are
endowed by our Creator with certain unalienable rights, life liberty and the pursuit of happiness.
2
This
reinforces our strong beliefs that liberty and freedom are Gods gift to us and that religious liberty and
religious expression are irreplaceable underpinnings to freedom in our democracy. I often look at the
picture in my home of General George Washington at Valley Forge kneeling in prayer in the snow with
his horse tied to the tree.
3
General Washington knew it was not enough for an individual or a society to
depend on their courage and their goodness, they must also seek help from God their preserver receive
our sincere gratitude for the traditional values in our nation that have remained viable through the past
centuries. Our American history teaches us that liberty and freedom prosper when religion and
spirituality are vibrant and that religion and freedom prosper when we understand the rule of law under
God is acknowledged.
And so, tonight, as we pledge our allegiance to our country and to our nations flag we say with
understanding one nation under God with liberty and justice for all. We are grateful that each of us can
be a part of this public city council meeting. We invoke your blessings upon each council member.
They are our friends whom we have freely elected and whom we pray for by name daily, cause each of
them to understand they cannot properly discharge their responsibilities or their assignments apart from
your enablement. Give them and their support staff the strength and the security of your invisible
presence. Give your divine direction in their thought processes for this will bring proper solutions to
each problem and each need that they encounter and in addition it will benefit each citizen and each
guest in our beautiful city. This invocation we pray in the name of our personal Savior and Lord.
Amen.
2
This is incorrect. The true wording is, We hold these truths to be self-evident, that all men are created equal, that they are
endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.
The clause refers not to our Creator, but to their Creator. The distinction is deliberate and important. If Jefferson, Adams,
and Franklin wished to refer to a specifically Judeo-Christian Creator they would not have chosen the latter. Their is a
possessive pronoun (e.g., their car or their rights as individuals) or an indefinite singular pronoun (e.g., some left their
book on the table.). Either way, in this context the use indicates a choice; that each individual has their own, valid view of
their Creator and it is not for the government to say which view is better. The is a definite article used with specifying
or particularizing effect. If Jefferson, Adams, and Franklin wished to specify or single out a particular Creator, the proper
phrase would be the Creator, or simply name the Creator. The use of their and not the before the noun indicates that
the writers were not speaking about a specific god.
3
Historians agree that this did not happen. There is no contemporaneous report to verify it and the original report is from
The Life of Washington, by Parson Mason Weems, who did not include the story until the 17
th
edition and also gave us the
myth of the cherry tree. See Edward G. Lengel, Inventing George Washington, 13, 22-23, 76-86 (Harper Collins Publishers,
2011).
3
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 5, 2008

Will you please bow your heart in prayer? Our Heavenly Father: we pause tonight to express our
gratitude for the gentle rains that has fallen on our community these past days. The ground has been
saturated the surrounding hills have become lush green providing grazing future for cattle and likewise
sheer beauty for us to enjoy. Rain was so needed on our California coast and you have sent rain and in
some areas more than normal. We say thank you for enlarging our water supply.

Today is primary election day better known as Super Tuesday. The citizens of many states from our
own California to Connecticut and from Idaho to Georgia are going to the polls to select candidates
who will lead our nation. Pres. Calvin Coolidge said in 1926, We live in a republic. This is
government by representation. If we are to have any measure of self-government, the voice of the
people is the rule. Therefore it is altogether necessary in each election that there should be a fairly full
participation by all the qualified voters." We pray tonight for each of those who are seeking public
office. May each of us, as citizens, not shirk our responsibility of citizenship and cast our vote, and
God, cause Your Will to be done. Do not withdraw your present help from us but forgive our sins so
that your divine favor will continue to be out poured upon our great nation. We are especially grateful
for your protection upon our country these years since 9/11 and we are so grateful for the continuing
efforts of our intelligence community whom you have used to protect our land and each American
citizen.

We ask that you will unite our hearts and strengthen our hands to work together as Americans for the
good of our city, our state and our nation. Continue to be our light and our guide our strength and our
courage. And may we so honor you that your promise and Holy Scripture will be fulfilled in us for
Scripture says, No weapon that is formed against you will prosper.
4
And tonight, we invoke your
blessings upon our city council members grant to them and their support staff the strength and the
security of your invisible presence. Give your divine direction for each decision that is made tonight.
Bring proper solutions to each new need and to each difficulty that our council will encounter. May
each citizen benefit as well as each guest who visits our beautiful city. This invocation we pray in the
name of our Savior and Lord. Amen.







4
Isaiah 54:17, No weapon that is formed against thee shall prosper; and every tongue that shall rise against thee in
judgment thou shalt condemn. This is the heritage of the servants of the LORD, and their righteousness is of me, saith the
LORD. This is a direct rebuke of the personal beliefs of all non-Christians.
4
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
February 19, 2008
Will you please bow your heart with me in prayer? Our Heavenly Father, just yesterday, we were
privileged to celebrate a national holiday, President's Day. We especially directed our thoughts to two
United States Presidents whose birthdays are in February, George Washington and Abraham Lincoln.
These were men who honored God, and led our nation in righteous ways. Although our nation faced
extremely troubled times, they led in integrity and in truth. They were men of character who were
concerned about doing right more than securing high approval ratings. They read often the Holy
Scriptures and found direction from them.
5
They were men of prayer and understood that they were
always answerable to you.
6
As such, they were courageous to walk in obedience and to do what you
required of them. The Bible teaches us Blessed is the nation whose God is the Lord.
7
Give to our
leaders the wisdom to know what is right, and the will to do it. Cause us to understand the words of
Lincoln when he said, I have been driven many times upon my knees by the overwhelming conviction
that I have nowhere else to go. My own wisdom seemed insufficient for the day. And so tonight, we
boldly declare our nation's motto, In God, we trust.
Let us never forget that God promises security and stability to all who put their trust in him, and history
teaches us that God chooses human instruments through whom he can infuse his life and his wisdom,
with spiritual and civil authority.
8
We are grateful for our City Council, and their support staff, and we
pray that you would infuse in them your wisdom and your understanding. Many problems they face
seem to defy a solution, but your wisdom causes confusion to fade into harmony, and when our hearts
and minds are turned to God in childlike trust, it is then that God the invisible enables us to complete
any assignment that he entrusts to us and to do it with courage and success. Tonight we invoke your
invisible presence and will to be the resource that you give to each of the leaders of our city. May
proper decisions be made tonight that will honor you and benefit the citizens and the guests of our
beautiful city. This invocation we pray in the name of our personal Savior and Lord. Amen.
5
Unfounded.
6
Unfounded.
7
Psalm 33:12.
8
See Romans 13.
5
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 4, 2008

Will you bow your heart with me in prayer please? Our Heavenly Father, When we read and reread the
words spoken by our national leaders of yesteryear, our hearts are filled with praise and thanks to you.
It was Franklin Delano Roosevelt, our 32nd president of the United States, who declared in a
nationwide radio broadcast in 1935, and I quote, we can not read the history of our rise and
development as a nation without reckoning with the place the Bible has occupied in shaping the
advances of our republic. When we have been the truest and the most consistent in obeying its precepts,
we have attained the greatest measure of contentment and prosperity. And six years later on January
16, 1941 he stated, The nation has placed its destiny in the hands and hearts of its millions of free men
and women and its faith in freedom under the guidance of God. Unquote. Our founding fathers
understood and put into practice the words of the profit Isaiah, written to his fellow citizens in chapter
54 verse 14 which says, you shall establish yourself in righteousness in conformity with Gods will
and order.
9


Grant that each of us, as citizens of our great nation and city tonight will determine to establish our
lives and our lifestyles and righteousness conforming daily to your divine will and order. Our godly
heritage revealed in the lives, decisions, and documents of so many who have helped to shape our
nation from its earliest years give us boldness tonight to declare our nations motto, in God we trust.

Were grateful to have freely elected our mayor and members of our city council. We pray for them
and undergird both them and their support staff with our words and our prayers daily. History teaches
us that good government originated in the heart of God and so tonight we invoke Gods divine wisdom
and courage to be freely given to each of them so that they shall make good and right decisions. May
each determination that is made bring esteem and righteousness toward God, and bring justice and
fairness and worth to each citizen and guest visiting our beautiful city. Grant our council your
continued blessings upon our intelligence community and grant your protection and your favor upon
each of our leaders and our citizens. We thank you for hearing and responding to this prayer of
invocation that we pray in the name of our personal Savior and Lord. Amen.

9
Isaiah 54:14, the prior verse reads And all thy children shall be taught of the Lord.
6
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 18, 2008

Our Heavenly Father, we lift our hearts in gratitude tonight that we are privileged to participate in our
public city council meeting. We offer praise to God for your continued protection over our nation and
our city. We pray that your omniscience and knowledge will be granted to our intelligence community.
As they continue to safeguard our country and our citizens. May no further terrorist plots be planned or
carried out and may any plans made to do us harm be uncovered and defused before they can be
realized. Cause righteousness to rein in our lives individually and in our government.

It was President Herbert Hoover, our 31st president who said, and I quote, When there is lack of honor
in government, the morals of the whole people are poisoned. There is no such thing as no-mans-land
between honesty and dishonesty. Our strength lies in spiritual concepts. It lies in public sensitivity to
evil. Our greatest dangers are not from invasion by foreign armies, but rather that we commit suicide
from within by complacence with evil or by public tolerance of scandalous behavior. unquote.

The power of prayer is at the dynamic force to repel unrighteousness, but the influence of prayer has
been dramatically reduced in our public life, and the moral compass of the Holy Scriptures has been
largely laid aside. Public morality is declining to dangerously low points. Help each of us to always
seek to live justly and to pursue righteousness and be zealous for lifestyles that honor God. Were most
grateful for our nations motto that strongly instructs us, in God we trust. Thank you for each member of
our city council and their support staff. Infuse in them your wisdom and your understanding. Give them
your solution to every difficulty that they face. We invoke your irresistible presence and will tonight to
become the resource that you graciously grant to each of the leaders of our city. May proper decisions
be made that will honor you and benefit the citizens and the guest of our beautiful city. This invocation
we pray in the name of our personal Savior and Lord. Amen
7
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
April 1, 2008
Will you please bow your heart with me in prayer? Our Heavenly Father, many of us alive today,
including myself remember well the many battles of World War II. It was December 1944, our
American forces were engaged in one of the largest land battles of the war. And commanding the one
half million soldiers of US Third Army was General George Patton. History says he could be tough and
stubborn and the very next moment, commune with God the divine. Hed been taught that courage is
fear that has said its prayers. He and his chief chaplain wrote a prayer and George Patton signed it and
sent it as a Christmas greeting to every commander and every soldier under his command, and I quote,
Almighty and merciful God, we humbly beseech you. Because of your great goodness, that you
restrain the immoderate reins with which weve had to contend. Give us fair weather for battle,
graciously hearken to us as soldiers who call upon you that armed with your power, we may advance
from victory to victory and crush the oppression and wickedness of our enemies and establish your
justice among men and nations. Amen.
And to the astonishment of Pattons soldiers the fog lifted, the rain stopped, and the weather cleared for
the critical period December 20 to January 1. General Patton said to his chief chaplain, Our prayers
worked. I knew they would. Im delighted by what I have seen as the work of divine providence
helping the Third US Army up until this moment. A letter was sent by the chief chaplain to every
commander of all four hundred and eighty six chaplains of the Third US Army, and it read, Urge your
men to pray. Not only in church, but elsewhere. Pray when driving, pray when fighting, pray when
alone, pray with others, pray by night, pray by day, pray by .. for victory, pray for our army, and pray
for peace. Be assured that this message on prayer has the approval the encouragement and the
enthusiastic support of the Third US Army commander, General George Patton.
So may each of us tonight, Our Father, as individual citizens be people of prayer. By night and by day,
many unfavorable situations exist from time to time in the lives of our citizens, in the lives of our city
but you have chosen human instruments through who you can infuse your divine life and wisdom with
spiritual and civil authority. Teach us and the members of our city council that it is when our hearts and
our minds are turned to God in childlike trust that your that you divinely enable us to complete any
assignment from you with courage and with success. Tonight, we invoke your presences and Your Will
to become the resource that you give to each of our elected leaders and their support staff. God bless
the citizens and the guest of our beautiful city. God bless America and protect America. This
invocation we pray in the name of our personal Savior and Lord. Amen.
8
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 15, 2008

Will you please join me in prayer? Our Heavenly Father, we offer our gratitude tonight that we are
citizens of our great nation, the United States of America. Our country is the hope of the oppressed.
Our country is the greatest force for good on the earth. By our actions we declare that freedom and
liberty is on the march. The earliest history of our nation teaches us that our pilgrim founding fathers
came here in search of religious freedom. Their faith and prayers and writings and lifestyles relate to us
that we were founded and continue to be one nation under God. And one of the most unique important
characteristics of our country is our own legacy of faith and trust in God, Yet there are some among us
who systematically try to censor or suppress our spiritual heritage. It was in August of 1984 that then-
President Ronald Reagan said, Without God there is no virtue because there is no prompting of the
conscience. Without God there is a coarsening of the society and without God democracy will not and
cannot long endure. And then he concluded by saying, If we ever forget that we are one nation under
God, then we will be a nation gone under. And so tonight, we reaffirm our nation's motto, In God we
Trust. And we would pray that you would continue to guide our intelligence community as they seek to
protect our nation and to protect us as citizens.

We acknowledge that your gracious guiding hand
10
has been seen in our land and our city of Pismo
Beach and we ask your blessings upon our mayor and the members of our city council. We have freely
elected our fellow citizens. These are our friends who serve us on our city council and as such assume
responsibility daily to pray for them by name. Our council members and their support staff seek
earnestly to make Pismo Beach a better place to live and to enjoy life with our family and with friends
and so tonight we would invoke the power of your eternal presence to cause their thought processes to
respond to your divine guidance. May the decisions that are made tonight honor you and be for the
betterment of each of us as citizens and all the guest who visit our beautiful city. This invocation we
pray in the name of our personal Savior and Lord. Amen


10
Nehemiah 2:18, see also, 1 Chronicles 4:10 Jabez cried out to the God of Israel, Oh, that you would bless me and
enlarge my territory! Let Your Hand be with me, and keep me from harm so that I will be free from pain. And God granted
his request. The Christian bible continually references its god as Your Hand. See, e.g., Psalm 21:7-8 For the king trusts
in the Lord; through the unfailing love of the Most High he will not be shaken. Your hand will lay hold on all your
enemies; your right hand will seize your foes.; Psalm 74:10-11 How long will the enemy mock you, O God? Will the foe
revile your name forever? Why do you hold back your hand, your right hand? Take it from the folds of your garment and
destroy them!; Micah 5:9 Your hand will be lifted up in triumph over your enemies, and all your foes will be destroyed.;
Psalm 139:5, 10; Deuteronomy 3:24; Isaiah 26:11; 1 Kings 8:24; 2 Chronicles 6:15; Acts 4:29-30; Psalm 17:14; Job 1:11;
Job 10:7.

9
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
May 6, 2008
Would you please bow your heart with me in prayer? Our Heavenly Father the beloved writer of Holy
Scripture, St. Paul, wrote to those of his day, saying, I urge you first of all to pray for all people. As
you make your request, ask for Gods mercy and give thanks and pray for all who are in authority so
that we may live in peace and quietness and in godliness and in dignity. For this is good, and this
pleases God.
11
St. Paul instructed each of us to pray for good government,
12
understanding that good
government is the will of God, so we pray tonight for our president, our senators, the members of the
House of Representatives. We also pray for our governor and state senators and state assembly persons.
It is clear that these guarantee our freedoms of speech and assembly, as well as maintaining law and
order, and allow unrestricted communication and travel.
We invoke your leadership upon each of them so they never ignore your guidance, nor spurn your holy
presence in either their lives or their leadership. May their plans for integrity and fairness to all be
evidenced in reality. Make each one to become righteous role models so that we and our children may
emulate them as they seek to aid the poor, the addicted, and safety of hope to all those who are in
despair. May each leader and citizen so earnestly seek Gods favor and righteousness that our
intelligence community will be used of God to thwart any plot or any device that would harm our
beloved nation or any of our citizenry. May we also join unitedly as one nation under God to boldly
declare: in God we trust. May our dedicated young servicemen and women stationed around the world
sense your presence and your protection as they guard us and guard our land, as they guard our
freedoms and our way of life.
We pray tonight especially for the leaders of our city. Our City Council; these are our friends whom we
have freely elected to govern us. We pray also for their support staff. May each of these leaders be led
and energized by your spirit and by your principles of righteousness. Give them wisdom and courage to
make right decisions. Stir and transform their minds, making them righteous and wise leaders. May
truth and integrity always rise above personal gain. May they honor you, oh God, and benefit each
citizen and each guest, and may each home and all those who live in it, and our beautiful city, be filled
with your majestic presence and your glory. This invocation we pray in the blessed name of our Savior
and Lord. Amen.
11
1 Timothy 2:1-3
12
Id.
10
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 20, 2008

Will you please stand and bow your heart with me? Our Heavenly Father, we express our gratefulness
for your blessings upon us and our beautiful city. At the same time, our hearts are strongly moved by
those who suffer much in Asia today. In China, there's been a devastating earthquake affecting
hundreds of thousands of people. And in Burma, the terrifying cyclone has caused upwards of one
hundred thousand deaths and those missing. With as many as 1 million losing their homes, as entire
villages were swept away. In this time of great suffering, we pray for the many victims. We remember
also many of our own citizens in Oklahoma, and Missouri, and Georgia, where storms and tornadoes
have caused damage and loss of life. Give strength and courage to those who have been so severely
impacted. On May 11, 1950, by joint resolution of Congress, Memorial Day was instituted. The
president was asked to call upon our citizens to unite in a day of prayer for permanent peace and
freedom and justice.

Next Monday our country will again celebrate Memorial Day. Our fallen servicemen and women have
given their lives to uphold the liberties that make our country a beacon of hope and freedom to people
everywhere. In Arlington, and Gettysburg, and cemeteries of which few have heard, each small marker
sanctifies the hallowed ground beneath and boasts the name of one who never sought fame, but served
our country unselfishly, not needing to be known. Bless their memories and their loved ones.

Tonight we thank you for each member of our city Council and their support staff. Infuse in them your
wisdom and your understanding. Give them your solution to each difficulty that they face, and we
would invoke your eternal presence and will to become the resource that you graciously grant to each
of the leaders of our citizens and our city. May proper decisions be made tonight that will honor you
and benefit the citizens and guest of our city. This invocation we pray in the blessed name of our
personal Savior and Lord. Amen.
11
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 3, 2008

May I ask you again this afternoon to bow your heart with me in prayer. Our Heavenly Father, it was
June 28, 1787 that Governor Benjamin Franklin of Pennsylvania hosted the 55 delegates in
Philadelphia to the Constitutional Convention. He said, I have lived a long time, and the longer I live
the more convincing proof I see of this truth; that God governs in the affairs of men. Without the
concurring aid of God we shall succeed in building this republic no better than the builders of Babel. I
therefore move that henceforth prayers, imploring the assistance of Heaven and its blessing on our
deliberations, to be held in this assembly every morning before we proceed to business, and that one or
more of the clergy of this city be requested to officiate in that service. James Madison concurred and
such resolution was passed,
13
and from that day until today, for the past 221 years, prayers have opened
both houses of Congress daily; in the United States Senate, and in our House of Representatives. And it
is in this spirit we pray this invocation tonight.

Were grateful for the privilege that we gather publicly in this Pismo Beach Council meeting. We
freely elected our mayor and her colleagues to our City Council, and in obedience to Holy Scripture,
we support them and undergird them and their staff with our prayers.
14
We pray for each of them
publicly tonight as we have prayed for each of them daily in our personal prayers. And we are
reminded again that good government is not an idea that is generated in the heart of people, but good
government is a principle that originated in the heart of God. So give to each of our Council persons
tonight your divine wisdom to make good decisions, and we would pray that you would grant that each
decision would honor God and be for the betterment of all the citizens of Pismo Beach and the guests
who visit our beautiful city. We thank you for hearing our prayer. This invocation we pray in the name
of our personal Savior and Lord. Amen.

13
This is simply not true. Franklin proposed the prayer and the motion died, it was so unimportant that the Congress did not
even vote on the issue.
14
1 Timothy 2:1-2.
12
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 17, 2008

Will you please bow your hearts with me in prayer? Our Heavenly Father, we are reminded tonight of
the words that were prayed by President Abraham Lincoln in 1863. It was during that time during the
Civil War when our beloved country so greatly needed your divine help and intervention, and President
Lincoln prayed, and I quote, It is the duty of Nations as well as men to hold their dependence upon the
overruling power of God, and to confess their sins and transgressions and humble sorrow, yet with
assured hope that general and genuine repentance will lead to mercy and to pardon, and to recognize
the sublime truths announced in the Holy Scriptures and proven by all history, that those nations only
are blessed whose God is the Lord. In this spirit we pray this invocation tonight we acknowledge your
divine providence Our Father, and we do desire to do Your Will. We are extremely grateful for all of
your benefits; for life, and for health, for friends, for prosperity, and we are so grateful that no attacks
have been on our homeland since 9/11.

This is the first Council meeting since our recent election day, two weeks ago today, the great majority
of our voting citizens saw the value of increasing our city sales tax by 1/2 cent. This brings us in line
with all of our neighboring cities, and will provide our counsel with an additional $1 million each year
to help maintain our infrastructure. We pray that city councils in the future will continue the same
degree of integrity as our current council manifests. For these additional funds, we give you thanks.
And in heartfelt humility we invoke your divine wisdom to be graciously bestowed upon every member
of the City Council. Grant that solutions to each problem and each need will come forth so that you,
our God, will be honored, and we, your people, will be benefited.

We pray again tonight the prayer of President Theodore Roosevelt when he prayed, We invoke the
direction and the favor of almighty God for our guidance and we do invoke your favor. We declare
our responsibility and our intention to pray daily for your leadership in the lives and the decisions of
each council member and the staff that supports them. Fill city hall and these council chambers with the
peace and the power of your divine presence. May each home, each citizen, and each guest feel the
impact of your powerful presence in our city. Thank you for responding to our united prayers. This
invocation we pray in the name of our personal Savior and Lord. Amen.
13
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
July 1, 2008
Will you please bow your heart with me in prayer? Our Heavenly Father, in 1789 President George
Washington said, It is the duty of all nations to acknowledge the providence of Almighty God. To
obey his will and to be grateful for his benefits and humbly implore Gods protection and favor. The
Holy Scriptures speak regarding King David; that he led Israel with the integrity of his heart, and the
skillfulness of his hands.
15
And when Nehemiah was mayor of Jerusalem, the Bible says of his brother
Hanani, that he was a faithful man who honored God more than many.
16

The Bible and history continually teach us that Gods favor accompanies righteousness and those who
live without compromise. For those who practice righteousness shine like beacons of light. Such
righteousness invariably affects positive social change. Cause each member of the City Council to
humbly seek the blessings in favor of God, that they may properly discharge their responsibilities and
the tasks that have been assigned to them. And as a result, may righteousness flow from City Hall and
from these council chambers into each home in our beautiful city and in the lives of each of our
citizens.
Thank you for your continued protection and provisions for our city and its citizens. We are grateful for
this open Council meeting, where all may participate in the affairs of our city. Bless all who work at
City Hall. Cause them to sense the strength and the security of your enabling presence. Grant our city
Council and their support staff your divine direction in their thought processes. May they receive your
solution for our problems and our needs that they encounter tonight. May each decision honor you and
benefit our citizens and the guests who come to our city. This invocation we pray in the name of our
personal Savior and Lord. Amen.
15
Psalm 78:72
16
The Bible says that Nehemiah put Hanani in charge because he feared God more than most men do. Nehemiah 7:2.
14
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

July 15, 2008
(Dr. Paul Toms)

Eternal God, our Heavenly Father, we begin our meeting today seeking your hand of blessing and
guidance
17
and direction. And we're thankful that we're able to do this. In some places in this world
where this is forbidden, we're grateful that we live in a place where freedom exists and reigns, and we
can worship as we sense our duty and responsibility. Bless our meeting today. Bless these people who
are elected and these who are appointed as officials for this community. We thank you for their
willingness to serve. We pray that you will grant wisdom and understanding and a sense of your
guiding hand and direction in these activities. And we would not forget to pray for people who are in
special need. Some in our community are in harms way. Bless people who are fighting the fires. Bless
people who are fighting wars. Bless people who are fighting hunger and depression and uneasiness
about the future. Thank you that you are able to meet our needs, and we look to you for guidance and
direction. So bless us today as we commend ourselves now into your loving care and seek your guiding
hand of blessing and direction
18
upon us. We pray in your Holy and Redemptive Name, amen.

17
See e.g., Isaiah 25:10, 66:14; Psalm 139:5.
18
See e.g., Isaiah 25:10, 66:14; Psalm 139:5.
15
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 5, 2008

Will you bow your heart in prayer please? Our Heavenly Father, James Madison was a principal author
of the United States Constitution. He was a father of the Bill of Rights, he was the fourth president of
the United States. It was he who said, "We have staked the whole future of American civilization not
upon the power of government, far from it, we have staked the future upon the capacity of each and all
of us to govern ourselves according to the Ten Commandments of God."
19
For these are fundamental
expressions of Gods design for man. And to abandon our nation's moorings would be tragic. And so
today we join our hearts with our American founding fathers of the past, whose vision and whose
courage has shaped the future of our great country. And today in true repentance, we ask you, our God,
to protect and to preserve our beloved country and cause our leaders to honor and to follow you.

Grant to each of our leaders nationally and locally clear courage and moral guidance as they make
decisions that directly influence our policies and our laws. Is recorded in Holy Scripture that King
Solomon declared in 930 B.C. "God is a shield to those who put their trust in him."
20
And again he
wrote, "He who trust in the Lord shall prosper."
21
And yet again he said, "Whoever trust in the Lord
shall be safe and secure."
22
And his father King David wrote before him, "He that trusteth in the Lord,
mercy shall compass him about."
23
Our forefathers read and reread these portions of Holy Scripture and
anchored their faith and their future to them. And as a result, president Abraham Lincoln in 1863 had
the words in God we trust engraved on each US coin. And later this phrase was authorized to be printed
on each piece of US paper currency. And in 1956, the United States Congress passed a resolution
declaring our national motto: in God we trust. And so today we boldly affirm our national motto: in
God we trust. And in this spirit we pray this invocation.

We are grateful that all of us may be a part of this public city Council meeting and we invoke your
blessings upon each council member. These are our friends. We have freely elected them to serve us
and we pray for them by name daily. Cause each of them to understand that they cannot properly
discharge their responsibilities or their assigned task apart from your divine enablement. Bless them
and their support staff with the strength and the security of your invisible presence. And grant to each
of them your divine direction in their thought processes. This will bring proper solutions to each need
and each problem that they encounter and will benefit each citizen and each guest in our beautiful city
of Pismo Beach. This invocation we pray in the name of our personal Savior and Lord. Amen.





19
This quote is false, or at least not attributable to James Madison. David Barton is responsible for putting this quote into
Christian pop-culture.
20
Proverbs 30:5, Every word of God is flawless; he is a shield to those who take refuge in him.
21
Proverbs 28:25, A greedy man stirs up dissension, but he who trusts in the LORD will prosper.
22
Proverbs 29:25
23
Psalm 32:10
16
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 19, 2008

Will you please bow your hearts with me in prayer? Our Heavenly Father, the first president of the
United States said, It is the duty of all nations to acknowledge the providence of Almighty God. To
obey his will and to be grateful for his benefits and to humbly implore his protection and favor. Years
later, James Madison, the fourth president of the United States, said, Before any man can be a member
of civil society he must be considered as a subject of the governor of the universe. The founding
leaders of our country believed wholeheartedly the words of Holy Scripture recorded in Psalm 33, "The
word of the Lord is right, the earth is full of the goodness of the Lord, and blessed is the nation
whose God is the Lord.
24
Because of this legacy left to succeeding generations, we understand more
fully why our U.S. Congress voted the motto of our nation to be: in God we trust. As American citizens
of this generation we forthrightly proclaim, In God we trust.

Cause us, Lord, to ever be mindful that no one is secure in their own accomplishments. Our positions
and our achievements never make us invincible. God promises security and stability to those who
choose to put their trust and their confidence in him. May we always seek to live justly and righteously
and be zealous for the things that honor God. Thank you for each member of our City Council and their
support staff. Infuse in them your wisdom and your understanding. Give your solution to every
difficulty and every need that they face. We invoke your irresistible presence and will tonight to
become the resource you graciously grant to each of the elected leaders of our city. May proper
decisions be made tonight that will honor you and will benefit the citizens and the guest of our
beautiful city. We pray especially your blessings upon our mayor, who is out of town, and upon our
mayor pro tem, as she leads our council meetings tonight. Give healing to all who were ill on our staff
and in our city. This invocation we pray in the name of our personal Savior and Lord. Amen.

24
There is no evidence to support this claim. The quotes are a mash of several verses: 4, 5, and 12. Others include verse 8,
Let all the earth fear the LORD; let all the people of the world revere him. Verse 10, The LORD foils the plans of the
nations; he thwarts the purposes of the peoples.
17
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
September 2, 2008
Will you please bow your hearts in prayer with me? Our Heavenly Father, as we bow our hearts in
prayer tonight, we remember the many of our fellow Americans whose lives have been so greatly
impacted by the hurricane Gustav. Many who live in the Gulf Coast on the southern border of our
nation have evacuated their homes and headed for higher ground and safety. Many will be returning
home shortly. Thank you that the newly constructed levees held so that destruction was far less than
might have been anticipated. Give to each of these your strength and your courage as they begin their
lives anew. Today with all our hearts we boldly affirm our nation's motto: in God we trust. These very
words are written over the entrance of US capitol building, and the Ten Commandments are engraved
in bronze on the floor of our National Archives, where our Declaration of Independence and U.S.
Constitution are on display. Our founding fathers carved words of praise to God in nearly every
building and monument and memorial in our capital city of Washington D.C.
25
They did not want
future Americans to ever forget that it was God who gave us liberty. For our godly heritage, we give
you our thanks. And in heartfelt humility we ask tonight for your continued presence, protection and
favor upon our nation. Bless all those in our intelligence community who serve untiringly to thwart any
enemy attacks.
We invoke your divine wisdom to be bestowed tonight on each member of our City Council. We ask
you to provide solutions to each problem and each need, so you will be honored and we will be
benefited. We declare our responsibility to pray daily for your leadership in the lives and decisions of
our council members and their support staff. We pray that you would fill City Hall and these council
chambers with the peace and the power of your divine presence. And may each home and each citizen
and each guest feel the impact of your presence in our city. We pray especially for those who are ill or
facing situations in which they have never been involved in heretofore. We invoke your divine
presence and power to strengthen and to energize them and their families. This invocation we pray in
the name of our personal Savior and Lord. Amen.
25
In God We Trust was carved into the Capitol, despite a lawsuit, in October, 2009. The cornerstone to the National
Archives was laid in February, 1933, the same decade as Supreme Court constructed. History of the National Archives
Building, National Archives website, http://www.archives.gov/about/history/building-an-archives/building.html (last
accessed, Feb. 1, 2013).
18
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 16, 2008

Let us bow our hearts in prayer. Our Heavenly Father, in our great country we recognize that prayer is
a gift from God to every human being. It is a gift that permits us to come before God as a creator, with
heartfelt worship and request as well as our deepest hopes. Prayer reminds us that when we bow our
hearts or fall on our knees, we are all equal in the eyes of the living God, the Almighty. In prayer, we
are assured that we are never alone, whether it be in times of personal difficulty or individual suffering.
This is why Benjamin Franklin proposed that the Constitutional Convention of 1787 began each day
with prayer. And out of this group of public leaders, who gave themselves to public prayer, was born
the Constitution of the United States, 221 years ago tomorrow; September 18, 1787.
26
And no legal
document has ever been written by man that has done so much good for so many people, and has
become the envy and the hope of every generation. Our founding fathers left us a legacy and a
testimony to the role of God in America's history. And the Holy Scriptures strongly teach us tonight:
blessed is the nation whose God is the Lord.
27
So once again we give our personal affirmation of our
nation's motto: in God we trust.

And in the dignity of this council meeting we invoke your divine wisdom and guidance to be upon our
mayor and her colleagues, as well as their support staff. May righteousness always fill our City Hall
and these council chambers so that each decision will be a good decision and this will honor you, our
God, and improve the lives of each citizen and guest in our beautiful city. Tonight we remember our
fellow Americans in Galveston and Houston Texas, who have suffered so much, and many who have
lost everything in hurricane Ike. Let them be strengthened and encouraged by our prayers and by your
abiding presence. In this invocation we pray in our Savior's Name. Amen.





26
This is simply not true. Franklin proposed the prayer and the motion died, it was so unimportant that the Congress did not
even vote on the issue.
27
Psalm 33:12
19
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 7, 2008
(recording partially missing)

... a public tolerance of scandalous behavior." End quote. The power of prayer is the dynamic force that
repels unrighteousness, but the influence of prayer has been dramatically reduced our public life, and
the moral compass of the Holy Scriptures has been largely laid aside. Public morality is declining to
dangerously low points. Help each of us to always seek to live justly and to pursue righteousness and to
be zealous for lifestyles that honor God. In the coming election in the next few days, in our city, may
our ballots be cast for leaders whose lifestyles have pursued integrity and righteousness. We are most
grateful for our nation's motto that strongly instructs us that; in God is our trust.

Thank you for each member of our City Council and their support staff. Infuse in them your wisdom
and your understanding. Give them your solution to every difficulty they face. We invoke your
irresistible presence and will tonight, to become the resource that you graciously grant to each of the
citizens of our city. May proper decisions be made tonight that will honor you and benefit the citizens
and the guest of our beautiful city. This invocation we pray in the name of our personal Savior and
Lord. Amen.


20
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 21, 2008

Will you please bow your heart with me in prayer? Our Heavenly Father, American history relates that
following the Revolutionary War, delegates from all of the colonies met in convention in Philadelphia,
1787. When the convention seemed on the verge of disbanding, with nothing having been
accomplished, colonial statesman Benjamin Franklin addressed the convention, and I quote, "In the
beginning of the contest with Britain, we daily had prayer in this room for divine protection. Have we
forgotten this powerful friend? Or do we imagine that we no longer need his assistance? I have lived a
long time, and the longer I live the more convincing proofs I see of this truth; that God governs in the
affairs of men. I therefore, henceforth, move that prayers imploring the assistance of heaven be held in
our assembly every morning before we proceed to business." End quote. And your wisdom did
appear,
28
and by September 12, 1789, 39 persons representing 13 colonies affixed their signatures to a
completed document; the Constitution of the United States. And our Constitution still functions today,
219 years later, giving stability and determination for every citizen.

Our Father, today is the last Pismo Beach City Council meeting before the coming election. Two weeks
from today, November 4th, as United States citizens, we will be electing a new president, a full House
of Representatives, and numerous senators. In our city of Pismo Beach, we will be electing our city
mayor, and two council members. Cause each of our citizens to accept their responsibility and privilege
to vote, and help us as individual citizens to elect leaders whose lifestyles and judgments have pursued
integrity and righteousness. For King Solomon wrote in the Holy Scriptures, "Righteousness exalts a
nation, but sin is a reproach to any people."
29
We pray today for our servicemen and women serving us
around the globe, protect them with your eternal power. We invoke your divine presence so that it may
fill City Hall daily as well as our city council chambers tonight. Give to each member of our City
Council and their support staff your wisdom and your understanding for matters at hand tonight and in
the future. God bless and protect America and our citizens in guest who visit our beautiful city of
Pismo beach. This invocation, invoking your divine leadership tonight, we pray in the name of our
personal Savior and Lord. Amen.



28
Ben Franklins proposal was ignored by the Congress, never even receiving a vote.
29
Proverbs 14:34.
21
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

November 18, 2008

Will you bow your heart with me in prayer? Our Heavenly Father, Karl Marx once said, If we can rip
history away from people, they will easily be conquered. For we know that a bouquet of roses die when
cut off from their roots.
30
So we clearly understand that no liberty and no freedom is secure when our
roots are removed. Those roots that have been determined by God. Ethics, morals, standards of
behavior, these are determined by God rather than majority of people. So tonight, enable each of us to
stand firm for our godly convictions, understanding it is an honor and a privilege to stand for right.
May the deep abiding sense of Gods holiness and Gods righteousness always determine our sense of
right and wrong. Tonight we strongly affirm our nation's motto; in God we trust.

Help us to maintain these and this firm conviction in our hearts and in our lifestyles. For only then we
will not be helpless or defenseless as we face the future; we will do it with confidence. Since our
council last met, we have elected a new president nationally as well as new leaders locally. We pray for
your wisdom and understanding to be granted to our current President, George W. Bush, as he
completes his presidency, and may your wisdom and understanding be granted in like manner to
President-elect Obama as he assumes his role to lead our nation.

Bless also those who have been elected to serve us in our beautiful city. We thank you for the privilege
of meeting together in this council meeting conducted openly in public for the benefits of our citizens.
We ask that your invisible presence will fill our City Hall daily, as well as our council chambers
tonight. We pray for each of our council members. These are our friends, we have freely elected them
to serve us, and to govern us. We pray for them publicly tonight because we pray for them by name
daily in our private prayers. Grant that each of our city council members, our mayor, and their support
staff will be generously given your divine wisdom and guidance for the matters at hand tonight and in
the future. God, bless America and protect our President, our military forces, our citizens of Pismo
Beach, and the guests to visit our beautiful city. We invoke your divine leadership tonight upon all who
lead our city. This invocation we pray, in the name of our personal Savior and Lord. Amen.

30
No source can be located for this quote, it appears fictional.
22
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 2, 2008

Will you please join your heart with me in prayer? Our Heavenly Father, we are grateful for the work
that has been accomplished by our current council in the previous councils before them. May your
blessings rest upon these dedicated citizens. Tonight, our newly elected council persons will be sworn
in. We receive our reelected Mayor and each member of our newly elected City Council as Gods gift
to us. We have freely elected them to lead us and to govern us. Cause each of them to understand that
their example to their family, their example to their business, and their example to our community
makes each of them a leader. And as such, may they always lead with integrity and transparency. For
integrity and character is our highest honor. Each member of our City Council is an example to our
community, when they are in session as the council, or when they move among us in our community.
So teach us and you that our personal example has everything to do with righteous influence. May they
remain calm and controlled even in difficult times, and as they do, may they manifest such uprightness;
demonstrating that in reality they are key pillars in our community. Let your unseen and irresistible
presence among us cause the work of our City Council and their support staff to be structured, to be
efficient, and father may it always be productive. Let there never be division or confusion, but may
they move together in such unity so as to function in the power of one.

We pray the prayer president Theodore Roosevelt in behalf of our new council when he prayed, and I
quote, "We invoke both the direction and the favor of Almighty God for our guidance." And tonight,
once again we reaffirm to you our nation's motto; in God we trust. May the continued nearness of your
presence and your divine guidance cause each decision that is made, first to honor you, and then to
cause our beautiful city to be a better place to live and to enjoy life. Each of these: benefits for our city,
all who live in it, and those who visit here. For these benefits we ask, we do it in the name of our
personal Savior and Lord. Amen.
23
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 16, 2008

Will you please bow your heart with me in prayer? Our Heavenly Father, it is Christmas time in our
city, and our surrounding community. Shops and stores are filled with carols and beautiful music of
Christmas. We want to thank you that you have prospered so many, that we may purchase gifts for
those we love and who are so dear to us. Allow your favored to rest upon our business community, who
have planned so earnestly and worked so diligently to sell their goods and services; and then probably
send sales tax and bed tax to our city treasury. For your favor, we are grateful.

Let us understand anew that the message of Christmas is simple and wonderful; God wants to enter into
all of life circumstances. And God does not choose a beginning point for his wonder-workings apart
from human beings. Everyone is important. We pray especially for those families among us tonight
whose lives have been impacted by the economic slowdown. We pray that you will graciously provide
for them and their families as only you know how. At this Christmas time, we also pray for all of our
military personnel, as they serve the noble causes of freedom and liberty around the world. May each
one who is deployed be safe and secure, and may their loved ones have Gods comfort and presence, as
families are separated one from the other.

When our next city Council meeting convenes, Christmas lights will be out, Christmas trees will have
faded, Christmas ribbons will have been forgotten, and Christmas carols and cards will have been
packed away. But the babe who was born in Bethlehem's manger will yet remain among us.
31
He will
comfort when we are sorrowful. He will provide meaning when life seems so useless and so empty. He
will bring light when the way seems dark, and he will provide joy when circumstances are grim. And
long after the carols have hushed and the gift certificates have been cashed, the babe that was born in
Bethlehem's manger will continue to bring happiness and satisfaction.
32


And tonight, we pray especially for those in our city who are ill, who are shut in, somewhat lonely. We
think of two such persons who have been so active in city activities but are not among us today; Elaine
Anthony's leg has been amputated below the knee and she is in a rest home in Morro Bay. Her husband
Art has serious problems with his throat and voice. We pray you will bring healing, and hope, and
restoration, and may these and many others sense our love for them. Tonight we invoke your divine
presence to fill City Hall daily and these council chambers especially tonight. Give your wisdom to our
mayor, and her colleagues, and their support staff for the matters that are hand tonight and in the future.
God bless America, protect our great country, protect the citizens in Pismo Beach, and protect the
guests who visit our beautiful city. This invocation we pray, this holy Christmas season, in the name of
our personal Savior and Lord. Amen.

31
Luke 2:12.
32
Luke 2:12.

24
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

January 6, 2009

May I ask that each of you bow your heart in prayer with me? Our Heavenly Father, today is the first
Council meeting in this new year of 2009. Many matters will be agendized and call for thoughtful
attention in the coming months. Some matters will be difficult to make an easy and simple decision, but
I well remember the day that President Franklin Roosevelt died in April 1945. Vice President Harry
Truman was immediately sworn into office as our new president and he addressed the combined US
Congress two days later April 16, 1945 with these words, "At this moment I have in my heart a prayer.
Almighty God, as I have assumed my heavy duties, I humbly pray the words of King Solomon: 'Give,
therefore, your servant and understanding heart to govern your people, that I may discern between good
and bad. For who is able to govern this so great a people?'"
33
And then Mr. Truman continued, "I ask
only to be a good and faithful servant of my Lord and my people." King Solomon, the world's wisest
political leader, also taught us that the hand of the diligent makes one rich, and he who walks in
integrity walks securely.
34


So let each of us hear clearly Gods call to daily live in integrity, and to live righteously. For this will
produce true freedom and true fulfillment, and it will produce lasting and eternal values. Thank you for
the leadership of police chief Joe Cortez and our City Police Department these past seven years. As he
enters his retirement years, let your blessing be upon him and upon his family. Our new police chief is
to be sworn in today. Cause your special favor to rest upon him as he seeks to maintain law and order
in our city. May your continued protection rest upon our city as the rule of law under God is
acknowledged. We invoke your wisdom to guide the thought processes of our mayor, her colleagues,
and their support staff tonight and in the future. May your solutions to each problem that they
encounter benefit each citizen and guest and our beautiful city in 2009. This invocation we pray in the
name of our personal Savior and Lord. Amen.



33
1 Kings 3:9
34
Proverbs 10:4-9.
25
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

January 20, 2009

Our Heavenly Father, today as American citizens, we witness the inauguration of the 44th President of
the United States, Mr. Barack Obama. You alone know the many great responsibilities that he now
faces, including our national economic downturn. We pray for him again this afternoon, as we have
prayed for him already this morning, and will pray for him each day, that he may daily seek your face
for your wisdom and for your guidance for the solution of our nation's affairs. Isaiah the great prophet
of yesteryear, spoke often to his nation, and to ever succeeding generations regarding the greatness of
Gods might, and the strength of Gods power.

Our national leaders have received vision and courage from these words. Grover Cleveland, the mayor
of Buffalo and later the governor of New York, was elected 24th president in 1893. Our nation then
faced conditions similar to those we now face. History teaches us that there was a treasury crisis, and
many farm mortgages were foreclosed on. There was high unemployment. But in his inaugural address,
President Cleveland clearly stated, "Let us not trust in human effort alone, but humbly acknowledge the
power and the goodness of Almighty God, who presides over the destiny of nations, and who at all
times has revealed in our country's history, himself. Therefore let us invoke his aid and his blessings
upon our labors. I know there is a supreme being who rules in the affairs of men, whose goodness and
mercy has followed the American people. He will not turn from us now if we humbly and reverently
seek his powerful aid."

And so tonight, with great courage and with great confidence, we as American citizens boldly declare
our nation's motto: in God we trust. By your great power, and by your great might, continue to protect
our nation and its citizens from those who seek to do us harm. Bless our intelligence community with
your favor and your fruitfulness. We invoke the dignity of your divine presence to fill these council
chambers tonight. Give your direction and your eternal counsel to our mayor, and her colleagues, and
their support staff. May each decision that is made bring honor to you, and bring fulfillment and
satisfaction to all who live in our beautiful city and who visit here. This invocation we pray in the name
of our personal Savior and Lord. Amen.
26
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 3, 2009
Rebecca McMurry

Will you all bow your heads? Our Heavenly Father, our U.S. history has taught us that justice John Jay,
the first U.S. Supreme Court Chief Justice, authorized prayer to be prayed to open U.S. Court sessions.
In this spirit, we offer to you this prayer of invocation. We are grateful for the privilege of public
gathering in our Pismo Beach City Council meeting this evening. We have selected our mayor and her
colleagues to our City Council. In obedience to Holy Scripture, we support them with our prayer, in
order that we may live a quiet and peaceful life in all godliness.
35
We pray for them publicly tonight,
having prayed for them by name in our personal prayers. May each member of our City Council accept
their responsibility to lead each of us as citizens with single-mindedness of purpose, and humility of
spirit; only then can we confidently anticipate favor and guidance of our eternal God. Guide us with
your eternal wisdom tonight, to make wise decisions that will honor you and better conditions for
citizens of our beautiful city. Tonight, we also lift up in prayer our city chaplain, Dr. Paul Jones, and
ask that your healing touch be placed upon him this night, and that he be made whole and well this very
moment. With your almighty help, we can resolve every problem that confronts us. Thank you for
hearing our prayers. We ask these things in the name of our Lord. Amen.

35
1 Timothy 2:1-2, I urge, then, first of all, that requests, prayers, intercession and thanksgiving be made for everyone
for kings and all those in authority, that we may live peaceful and quiet lives in all godliness and holiness.
27
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 17, 2009

Will you please bow your heart with me in prayer? Our Heavenly Father, Thomas Jefferson was the
primary author of our Declaration of Independence, and the third president of the United States. In a
prayer March 4, 1805, he prayed, "Almighty God, may we always prove ourselves to be a people
mindful of your favor and glad to do Your Will. Save us from violence, and confusion, and pride, and
arrogance, and from every evil way. Endow with your spirit of wisdom, those we entrust with the
authority of government, that there may be justice and peace, and through obedience to Your Word, we
may show forth your praise among the nations of the world. God, who gave us life, gave us liberty, can
the liberties of a nation be thought secure when we remove the conviction in the minds of people, that
these liberties are the gift of God?"
36
We thank you, Our Father, for the freedoms and liberties that we
as Americans enjoy tonight. We're mindful that they are gifts of God. Help us to dedicate ourselves
individually, to honor righteousness, and always be glad to do Your Will. Let us always affirm our
nation's motto wholeheartedly; in God we trust.

We are privileged to meet together in this public City Council meeting. We are grateful for every
member of our City Council; these are our friends whom we have freely elected to govern our city, and
we pray for them daily by name, that they may lead us in integrity and transparency. We invoke your
divine wisdom upon each of them and their support staff. May Your Will be done, and may your name
be honored in each decision that is made. Be mindful, with your enablement and your assistance, of
each individual, and each business that are affected by the current economic conditions in our city and
our land. And accept our thanks for the intelligence community, continue to work though them, and
cause us to live righteous lives daily, so that we may enjoy your protection from all who would do us
harm. This invocation we pray in the name of our personal Savior and Lord. Amen.

36
According to the Thomas Jefferson Foundation, which runs and maintains Jeffersons estate at Monticello, This prayer
was not written or delivered by Thomas Jefferson. It is in fact from the 1928 United States Book of Common Prayer.
http://www.monticello.org/site/research-and-collections/national-prayer-peace
28
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 3, 2009

Our Heavenly Father, President Calvin Coolidge, the 29th president of the United States, once said, "If
American democracy is to remain the greatest hope of humanity, it must continue abundantly in the
faith of the Bible." In the Bible, Isaiah the Prophet declared "The ways of the Lord are righteousness,
and the righteous will walk in them."
37
The Bible constantly encourages righteous living on the part of
each of us. Help us to display the character of God in our daily living and in our lifestyles. This will
cause us to be an expression of Gods love, and Gods compassion, and all we do. May we determine to
live and walk in obedience to the Bible. This will cause us to pursue righteousness and value godliness,
as each of us seeks Gods presence to surround us, and to surround our city, and our country. This will
produce reality for the present and promise for our future.

We hear again the prayer of President Theodore Roosevelt, who prayed, "We invoke the direction and
the favor of God the Almighty for our guidance." So we pray each citizen of our beloved city will seek
the guidance of God in our lives and in our actions. We pray earnestly this day for each individual and
each family whose lives have been negatively impacted and disrupted by our current economic
downturn. Many are earnestly praying and seeking for answers and solutions. Fulfill the promise of the
Bible to them; that God would be a shelter to your people and strength to those who put their trust in
you.

Cause each lady and gentlemen who we have elected to our City Council, and their support staff, to be
sincere and upright. May their convictions be firm and straight as the columns of our National
Cathedral. We invoke your divine wisdom and guidance for each matter brought before our City
Council tonight. May each decision honor God and benefit each citizen and each guest. This
invocation, in which we invoke your invisible presence and your leadership, we pray in the name of our
personal Redeemer and Lord. Amen.




37
Isaiah 26:7
29
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
March 17, 2009
Will you please bow your heart with me? Our Heavenly Father, it was Franklin Roosevelt, our 32nd
US president, who said, "We cannot read the history of the rise and development of our nation without
reckoning the place the Bible has occupied in shaping the advances in our republic. Where we have
been the truest and the most consistent in obeying its precepts, we obtain the greatest measure of
contentment and prosperity." And so, Our Father, your faithfulness to us has been as dependable as the
sun that rises each morning. The hillsides and the meadows in our region are lush with new green
growth because of the recent rains that you have sent. We are most grateful. Grant that we may sew
righteousness in our lives, that we may reap your faithfulness and your mercy. May we never resist
Gods will in our lives but, rather, may we value godliness and pursue righteousness each day. For the
Bible teaches us that righteousness and right living are essential to a healthy society. May we seek the
Lord and obey the Bible, so as to walk daily in the purity of Gods ways. Cause us to make godliness,
as recorded in the Scripture, to be our life's standards. Then, God will be our strength, he will be our
shelter, and he will dwell among us and he will cause us to prosper. Is in this spirit we boldly affirm
our nation's motto: in God we trust.
We give you thanks for the leaders and the actions of our current City Council. Cause our mayor, her
colleagues, and their support staff to sense your divine leadership and wisdom in each decision that
they make. Continue to provide your understanding and your resources to accomplish Your Will in our
beautiful city, even as Your Will is done in heaven. We pray especially for our mayor who is not with
us tonight, but is on business in our nation's capital. Give her your favor. May she increase in wisdom
and in favor with God, and with man, as she carries out her duties in Washington D.C. May a spirit of
unity continue to prevail at all levels of our city government. We invoke your unseen presence in every
deliberation tonight. We remember again, publicly, those who are hurting because of the economic
downturn both in our nation and our community. Some have had their work hours reduced. Others have
lost their jobs. And some of the businesses in our community are suffering economically. We ask you
to bring a speedy solution. And cause each of us, as individuals and as a nation, to repent of our sins
and turn wholeheartedly to honor you and to serve you. This invocation we pray in the name of our
Blessed Redeemer and Lord. Amen.
30
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 7, 2009

Will you bow your hearts with me in prayer please? Our Heavenly Father, we lift our hearts and
gratitude tonight that we are privileged to participate in our public City Council meeting. We offer
praise to God for your continued protection over our nation and our city. We pray that your
omniscience and your knowledge will be granted to our intelligence community, as they continue to
safeguard our country and our citizens. May no further terrorist plots be carried out, and may any plans
made to do us harm be uncovered and defused before they can be realized. Cause righteousness to reign
in our lives individually, and in our government. It was President Herbert Hoover, our thirty first
president who said, "When there is a lack of honor in government, the morals of the whole people are
poisoned. There is no such thing as no man's land between honesty and dishonesty. Our strength lies in
spiritual concepts. It lies in public sensitivity to evil. And our greatest dangers are not from invasions
by foreign armies, but rather that we commit suicide from within by complaisance with evil and by the
public tolerance of scandalous behavior." The power of prayer is the dynamic force that repels
unrighteousness. But the influence of prayer has been dramatically reduced in our public life, and the
moral compass of the Holy Scriptures has been largely laid aside. Public morality is declining
dangerously. Help each of us to make sure that we live justly, and pursue righteousness, and be zealous
for lifestyles that honor God. We are most grateful for our nation's motto that strongly instructs us: in
God we trust.

Thank you for each member our City Council and their support staff, infuse in them your wisdom and
your understanding. Give them your solution to every difficulty that they face, and we invoke your
irresistible presence and will tonight that it will become the resource that you graciously grant to each
of the leaders of our city. May proper decisions be made tonight that will honor you and benefit the
citizens and the guest of our beautiful city. This invocation we pray in the name of our personal Savior
and Lord. Amen.
31
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 21, 2009

Would you please bow your heart with me in prayer? Our Heavenly Father, our third president,
Thomas Jefferson, spoke to our nation in 1781. He said, "God who gave us life, gave us liberty, can the
liberties of a nation be thought secure when we removed their only firm basis; a conviction in the
minds of the people that these liberties are a gift of God."
38
And it was our 24th president, Grover
Cleveland, who said, "Above all, I know there is a supreme being who rules the affairs of men, and
whose goodness and mercy have always followed the American people. And I know he will not turn
from us now if we humbly and reverently seek his powerful aid." This is the spirit in which we pray
this invocation tonight. We're grateful that our United States Congress passed a resolution in 1954
stating: We are one nation under God. And two years later in 1956, stated our national motto will be: in
God we trust. And so again tonight we boldly affirm our nation's motto: in God we trust.

We invoke your blessings upon the city of Pismo Beach, all who live here, and all the guests to visit
here. Release your blessings upon all who work at City Hall, and serve our community so faithfully.
Cause each one to sense the strength and the security of your invisible presence, and give your eternal
wisdom to our friends, whom we have freely elected to serve us on our City Council. From day-to-day,
help them as they endeavor to make Pismo Beach a better place to live and to enjoy life. Especially
tonight, give your divine guidance in the thought processes of our mayor and each of her council
colleagues. May the decisions that are made honor you and be for the betterment of all of our citizens
and our guests. This invocation we pray in the name of our personal Savior and Lord. Amen.

38
Jefferson actually wrote this in two separate places more than 10 years apart.
1) The god who gave us life gave us liberty is from A Summary View of the Rights of British America (1774).
But let them [members of the parliament of Great Britain] not think to exclude us from going to other markets, to
dispose of those commodities which they cannot use, nor to supply those wants which they cannot supply. Still less
let it be proposed that our properties within our own territories shall be taxed or regulated by any power on earth
but our own. The god who gave us life gave us liberty at the same time: the hand of force may destroy, but cannot
disjoin them.
2) can the liberties Gift of God is from Notes on the State of Virginia, Query XVIII (1785). For in a warm
climate, no man will labour for himself who can make another labour for him. This is so true, that of the
proprietors of slaves a very small proportion indeed are ever seen to labor. And can the liberties of a nation be
thought secure when we have removed their only firm basis, a conviction in the minds of the people that these
liberties are the gift of God? That they are not to be violated but with his wrath? Indeed I tremble for my country
when I reflect that God is just: that his justice cannot sleep for ever . . .
32
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 5, 2009

Will you please bow your heart in prayer? Our Heavenly Father, President Calvin Coolidge, our 30th
President of the United States, said, "If American democracy is to remain the greatest hope of
humanity, it must continue abundantly in the faith of the Bible." And the leaders of our nation later
believed this strongly, for in 1952, by a joint resolution of Congress, the first Thursday in May each
year was designated as a national day of prayer. This day was designated as a day of focused prayer for
our nation, and its day after tomorrow Thursday, May 7 is the first Thursday of May. Each of us are
privileged to be a part in our own way in this annual observance of our national day of prayer.

And God is always true to his character, as we seek his face and prayer and respond to his holy promise
in the Scriptures, it will change the way we think and the way we behave. For sin and spiritual decline
removes the favor of God, but if we repent, God will forgive and pardon our sins, and replace them
with his righteousness in our lives. Each day we rest upon the unfailing promise found in the scriptures,
Isaiah 41:10, "Fear not for I am with you. Be not dismayed, for I am your God. I will strengthen you, I
will help you, I will uphold you with my righteous right hand." Knowing this, we confidently affirm
our nation's motto: in God we trust.

And in heartfelt humility, we ask tonight for your protection and your favor upon our nation and our
citizens. We especially pray for those who are ill and shut in. We would not forget to pray especially
today for one who attends almost every Council meeting and speaks frequently from this podium.
Because of his interest in our city and its future, we pray for Tony Spinelli, one of our citizens who's
been so ill. Will you allow the healing grace of God to flow through his body, and may healing be
swiftly and completely in his body. We pray also for those who are being adversely affected by the
economic slowdown. We ask your divine presence and power to comfort and strengthen them and their
families. And we invoke your divine wisdom to be bestowed on each member of our City Council. We
ask you to provide solutions to each problem and to each need that they face tonight. We declare our
responsibility to pray for your leadership in the lives and decisions of each member of our City
Council, and their support staff. Fill City Hall and these council chambers with the peace and the power
of your divine presence. May each home, each citizen, and each guest sense the impact of your
presence in our city. This invocation we pray in the name of our personal Savior and Lord. Amen.












33
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 19, 2009
Dr. Paul Toms, recording partially missing

... Thank you for the people who lead us. Thank you with the people who act as our friends and help us
day by day. Guide us now in this meeting. May the decisions that are made and all the processes that
are followed be in keeping with your plan, and with Your Will. We ask these things in the name of
Your Son and our Savior. Amen.
34
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 2, 2009
recording partially missing

Pray for the army, and pray for peace, and be assured that this message on prayer has the approval,
the encouragement, and the enthusiastic support of the third U.S. Army commander, General George
Patton.

And so tonight, Our Father, may each of us as individual citizens be people of prayer by day and night.
Many unfavorable situations exist from time to time, in the lives of our citizens and in the life of our
city. You have chosen human instruments, through whom you can infuse your divine life and your
wisdom, with spiritual and civil authority. So teach us, and the members of our City Council, that it is
when our hearts and minds are turned to God in childlike trust, that you divinely enable us to complete
any assignment from you, with courage and with success. Tonight we invoke your presence and Your
Will to become the resource that you give to each of our elected leaders and their support staff. God,
bless our citizens and the guests of our beautiful city. God bless America, and protect America. This
invocation we pray in the name of our personal Savior and Lord. Amen.




35
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 16, 2009

Will you bow your heart with me in prayer? Our Heavenly Father, Karl Marx once said, "If we can rip
away history from any people, then we will easily conquer them. We have learned that a bouquet of
beautiful roses soon die because they are cut off from their roots."
39
Ethics and moral standards of
behavior are not to be determined by a majority of people, but by God himself. It was President Harry
Truman who said, "The fundamental basics of this nation's laws was given to Moses on the Mount, and
the fundamental basis of our Bill of Rights comes from the teachings of Exodus, Isaiah, St. Matthew,
and St. Paul."

Let none of us believe the misconception that freedom is a license to sin, or that freedom is a license to
go our own way, or the misconception that freedom is a license to do as we wish. Help us to understand
that freedom is the responsibility and the power to do what is right. No liberty is secure when it is
removed from the roots that have been established by God. Our U.S. Constitution was written by moral
people, and it was written for moral people, and it will work for no other but moral people. Our
forefathers conceived freedom in their hearts, and they wrote freedom on our documents, and yet
freedom is not free. Our freedoms cannot survive without our personal responsibility and courage. Our
freedoms cannot survive without our eternal vigilance. So help each of our civic leaders and each of us
as citizens to stand firm. Let us never be intimidated by numbers, but cause us to be men and women of
conviction, who value moral righteousness above popular acclaim. Grant the light of your irresistible
presence to avail, so that no unrighteousness can prevail. As loyal citizens, we boldly proclaim our
nation's motto: in God we trust.

We invoke your favor upon our city of Pismo Beach. As we confess our sins and forsake our sins,
release your blessings upon each of our citizens, and all who work at City Hall and serve our
community. Give your eternal wisdom to our friends whom we have freely elected to serve on our City
Council, for these we pray for daily by name. Help them as they endeavor to make Pismo Beach a
better place to live and to enjoy life. Especially this evening, give your divine guidance to our mayor,
and each council member, and their support staff. This invocation we pray in the name of our personal
Savior and Lord. Amen.

39
No source can be located for this quote, it appears fictional.
36
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

July 7, 2009

Will you please bow your heart with me in prayer? Our Heavenly Father, the past several days we have
relived some of the history of our great nation, and the enumerable blessings of freedom that we enjoy.
The Declaration of Independence has rightly been called 'the birth certificate of our United States'. It
was approved by the Continental Congress, July 4, 1776, and by August 2, 56 legislators had affixed
their signatures. Many of the signers of the Declaration of Independence were men of strong godly
influence. 29 of the 56 signers had ordained ministerial credentials.
40
The first meeting of the
Continental Congress convened September 6, 1774, and the first three hours were dedicated to prayer,
followed by a study of Psalms 35. The Congress called for 3 million colonists to participate in a
national day of prayer and fasting, for Gods favor, as they faced the highly trained British Army and
Navy in their quest to overrun and defeat the 13 colonies.

General George Washington later said, The hand of divine providence became so conspicuous. For in
1781, General Washington forced the surrender of General Cornwallis at the Battle of Yorktown,
ending the Revolutionary War. And by Congressional approval, 20,000 Bibles were printed in 1782,
41

and placed in public schools to be used regularly in the classroom, and this practice continued for 181
years, until June 1963 when the U.S. Supreme Court forbid the practice to continue.
42
President
Andrew Jackson said, The Bible is the rock upon which our republic rests.
43



40
This myth comes from David Barton, who claimed the 29 signers had seminary degrees. Only one, John Witherspoon
was a minister. Three others, Lyman Hall, Robert Treat Paine and William Williams, studied for but did not go into the
ministry (Hall quit theology to become a doctor). See, e.g., Elise Hu and Barbara Bradley Hagerty, Cue the Tape: How
David Barton Sees the World, National Public Radio, (August 8, 2012) available at
http://www.npr.org/2012/08/02/157777697/cue-the-tape-how-david-barton-sees-the-world (last accessed, February 1,
2013).
41
Congress never printed Bible. During the Revolutionary War, a printer, Robert Aitken, asked to publish a Bible under the
authority of Congress and to be commissioned by Congress to do so. Congress declined to do this but did recommend this
edition, in part because it was an instance of the progress of arts in this country. Gaillard Hunt, ed., Journals of the
Continental Congress, 1774-1789, vol. 23, (Washington D.C.: Government Printing Office, 1914), 574. Printing in this
country was important because of the British embargo. Aitken used the congressional recommendation to hawk his bibles
but, by his own account, they sold so poorly that he lost over 3,000 on the endeavor and could not get Congress to
reimburse him or buy the bibles. Robert Aitken to George Washington, June 9, 1790, George Washington Papers at the
Library of Congress, 1741-1799: Series 4, General Correspondence.
42
This is not true. Congress did not place or approve the placement of Bibles in public schools and many state courts
booted the Bible prior to 1963. See, e.g., Weiss v. District Board, 44 N.W. 967, 981 (1890); Herold v. Parish Board of
School Directors, 136 La. 1034, 1049-1050, 68 So. 116, 121, L.R.A.1915D, 941 (1915); State v. Scheve, 65 Neb. 853, 91
N.W. 846 (1902) aff'd, 65 Neb. 853, 93 N.W. 169 (1903);Tudor v. Board of Education, 14 N.J. 31, 48-52, 100 A.2d 857,
867-868, 45 A.L.R.2d 729 (1953); Brown v. Orange County Board of Public Instruction, 128 So.2d 181, 185 (Fla.App.,
1960);
43
No primary source provided or discernable. The earliest located source is Frederic William Farrar, History of
Interpretation: eight lectures preached before the University of Oxford in the year MDCCCLXXXV on the foundation of the
late Rev. John Bampton, page xxvii(MacMillian and Co., London, 1886),
http://books.google.com/books?id=kVX92B3TRkMC&printsec=frontcover&source=gbs_ge_summary_r&cad=0#v=onepag
e&q&f=false. According to the title page, Farrar was Archdeacon and Canon of Westminster and Chaplain in Ordinary to
the Queen. The Jackson quote is buried in a paragraph that begins, My main wish has been to show the true basis whereon
rests the sacredness of Holy Scripture It is because there is no Book and no Literature which can for a moment supply the
place of the Bible in the moral and spiritual education of mankind that I would do my utmost to save it from the injury of
false theories and impossible interpretations. Although Farrar cites several sources just a few pages earlier, no source is
provided for the deathbed quote by Jackson: That book sir, said the American President, Andrew Jackson, pointing to
the family Bible during his last illness, is the rock on which our Republic rests.
37
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

Today, in the troubled times that our nation and our world faces, help each one of us to follow the
principles of our founding fathers. May we humbly confess our sin, and seek the wisdom and the aid of
our eternal God. For the Holy Scriptures state, The eyes of the Lord are upon the righteous, and his
ears are open to their cry.
44
Many unfavorable circumstances exist from time to time in the lives of
numerous citizens in our community. We are so grateful for the members of our City Council and their
support staff, from whom you can infuse your divine wisdom and your divine life, and we join with
them in invoking your divine presence and your divine will, to be the resource that becomes the
solution to every situation that we face. God, bless the citizens and the guests of our beautiful city, and
God bless and protect our country: America. This invocation we pray in the name of our personal
Savior and Lord. Amen.




44
Psalm 34:15

38
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

July 21, 2009
(recording partially missing)

...upon our city of Pismo Beach. As we confess and forsake our sins, release your blessings upon each
of our citizens and all who work at City Hall, and serve our community. Give your eternal wisdom to
each member of our City Council, these are friends whom we have freely elected to govern our city,
and for these we pray daily by name. Assess them, as they endeavor to make our beautiful city a better
place to live and to enjoy life. Especially this evening, give your divine wisdom to our mayor, her
colleagues on the council, and their support staff. This invocation we pray in the name of our personal
Savior and Lord. Amen.
39
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 4, 2009

Will you please bow your heart with me in prayer? Our Heavenly Father, America's founding fathers
gave us a constitutional republic, and because of the wisdom and conviction of these righteous people,
we are free today. But let us never forget that we could die slaves if we lose sight and understanding of
the basic truth that freedom cannot exist without morality. Immoral men and women cannot long
endure, and will cease to exist, and history is filled with such examples. Character and moral fortitude
is a requirement, if we are to be able to govern ourselves. Whenever morality and righteous lifestyles
decline, the abuse of rights always increase. To abandon moral principles and to abandon
righteousness, we will lose our freedoms, for our rights come from God, and God gave certain
inalienable rights before any human government ever existed. People joined together to form human
governments in order to protect these rights, not to grant us rights, or to legislate out of existence these
inalienable rights. Make us men and women who are unintimidated [sic], and who value moral
righteousness above public acclaim.

It was George Washington, our first president, who said, "It is impossible to rightly govern without
God and the Bible."
45
And all 50 states in our United States, without exception, acknowledge God in
their state constitution. In 1879, when our own California State Constitution was written, the preamble
began by saying, "We the people of the state of California are grateful to Almighty God for our
freedom." Tonight, we feel much like President William McKinley, our 25th president, who declared in
his 1897 inaugural address, "I assume the responsible duties as President of the United States, relying
on the support of my countrymen and invoking the guidance of Almighty God."

In this public City Council meeting tonight, we invoke the wisdom and the guidance of Almighty God
to illuminate the thought processes of each of our council members. We have freely elected them to
govern us, and therefore we pray for them daily by name. Help each of them; our mayor, her
colleagues, and their support staff, as they endeavor to make wise decisions. And since you transmit
your blessings and your favor through headship, allow your favor to flow from City Hall, and from
these council chambers, to every home, and into every citizen who resides in our city, and every guest
who visits our city. Cause our beautiful city of Pismo Beach that borders the blue Pacific, to become a
better place to live and to enjoy life. This invocation we pray in the name of our personal Savior and
Lord. Amen.

45
Washington never said or wrote this phrase. See Paul Boller and John H. George, They Never Said It: A Book of Fake
Quotes, Misquotes, and Misleading Attributions, 126-7 (Oxford University Press, 1989).
40
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 18, 2009
(Dr. Paul Toms)

Will you join with me in a word of prayer please? Eternal God, Our Father, it is right and proper that
we should begin an important and significant meeting such as this, seeking your blessing and your hand
of guidance
46
upon us. Thank you for all that you do for us. Thank you that we have food and shelter.
Thank you that we have people who help us and sustain us. Thank you for friends who encourage us.
Thank you for this community. We pray today your rich and abiding and continued blessing upon this
community. And bless, we pray, and is fitting and proper that we should ask this, we pray for your
blessing upon those who lead us. You have told us in Your Word that we should pray for those who
have authority over us.
47


Authority has been granted to this counsel, and to other people represented here today by the people of
the community. Bless them as they exercise that authority. Give to them wisdom and understanding,
and may we continue to live in a peaceful and quiet situation. Bless those who help us. Bless the
children and youth of our community. Bless their teachers as they begin another school year, guide and
direct in their influence and their lives. Bless those who protect us, our firemen and our police people.
Watch over them. Help them as they protect us, may they be protected as well. Bless each member of
this counsel, and all the officers, people who are assigned responsibilities, and all of us as we represent
the community. We commend this meeting into your loving care. We seek Your Hand of blessing and
guidance
48
upon us, and we ask you to all to thank giving through Christ our Lord. Amen.




46
See e.g., Isaiah 25:10, 66:14; Psalm 139:5.
47
1 Timothy 2:1-2
48
See e.g., Isaiah 25:10, 66:14; Psalm 139:5.
41
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 1, 2009

May I ask you to bow your heart with me in prayer please? Our Heavenly Father, nearly 8 years have
come and gone since the day of infamy: 9-11-2001. On this day, 19 foreign born terrorists recognized
the vulnerability of our beloved nation, and they seized U.S. commercial airliners in midair, and filled
with thousands of gallons of high octane jet fuel, they slammed them into both towers of the World
Trade Center in New York City, and another airliner was flown into the nerve center of our U.S.
military, the Pentagon, in Washington D.C., and nearly 3,000 innocent people were killed. Before our
next official City Council meeting, September 11, 2009 will be upon us, in just 10 days, many of us
will be participating in memorial services. On this day, we will be remembering those who grieve,
because of the lives of loved ones, as well as those who are infirmed, physically and mentally, from
this cowardly attack. Following that 9/11 attack, members of both the Senate and the House of
Representatives met voluntarily for two hours in the rotunda of the capital building to humbly seek the
favor of God, asking for the forgiveness of our sins, and for reconciliation and unity. They believe such
assist our nation, to realize our potential as the champion of hope, the vindicator of the defenseless, and
the guardian of freedom. Our President and all nine Supreme Court Justices were invited to this time of
prayer, with no reporters or T.V. cameras, so that each could pray unhindered to God. It is in this spirit
that we pray this invocation tonight, for tonight, tens of thousands of our finest youth and military
leaders are in Afghanistan and Iraq, seeking to bring peace and prosperity to a people that have been
formerly oppressed.

It was Thomas Jefferson, our third president, who said, "The tree of freedom is watered by the blood of
every generation." And so tonight, we pray earnestly for our President Obama, and his advisers, and
every member of Congress. We pray for our servicemen and women. Protect them with the power of
your divine presence. And we pray for the families and loved ones who grieve, because of those who
paid the supreme sacrifice of their lives. And we stand tonight and affirm our national motto: in God
we trust. Especially tonight, our hearts go out to all those who suffer so much because of the inferno of
uncontrollable fires that burned so fiercely, especially in Southern California. We ask that you would
protect our firemen, who willingly give their all to protect our homes and our businesses. Cause these
fires to quickly burn themselves out. We ask your divine presence to fill our City Hall daily, and to fill
our council chambers tonight. Give to each member of our City Council your divine wisdom and your
divine guidance for the matters at hand tonight and in the future. God, bless and protect America, our
citizens and the guests who visit our beautiful city. This invocation, invoking your divine leadership
tonight, we pray in the name of our personal Savior and Lord. Amen.
42
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 15, 2009

May I invite you to bow your hearts with me in prayer? Our Heavenly Father, throughout our nation's
history, our leaders have invoked the aid of divine providence during the moments of trial and war.
Perhaps nothing exemplifies this more than the image of George Washington kneeling in the snow in
prayer during the terrible winter of 1776 at Valley Forge.
49
Honoring this heritage, in years after World
War II, Congress added the words: "under God" to our Pledge of Allegiance in 1954, and made the
words: in God we trust, our nation's motto in 1956. And so it is in this spirit that I offer this invocation
tonight. May we, our lawmakers in Washington D.C., as well as the members of our City Council in
Pismo Beach, be often reminded that America is still one nation under God, and may me remember that
God will continue to bless our nation, only as long as we boldly affirm our nation's motto with all our
hearts: in God we trust.

Grant that each citizen, each of our leaders, will seek to be people of conviction who value moral
righteousness above public acclaim. May we as individuals never forget that it is our unified prayers,
seeing Gods protection and seeking his blessing, that we are our greatest shield from the dangers and
threats that we face. Give to each of us a new fidelity, a new integrity, and a deeper purity. For only
then will the fullness of your purpose and your ways be revealed in each of us. Tonight, in the dignity
of this City Council meeting, guide our mayor and her colleagues whom we have freely elected to serve
as our leaders. We pray for them tonight publicly, because we have already prayed for each one by
name today in our prayers. We ask that you would crown this council meeting, and our community,
with the nearness of your invisible presence. Give your divine guidance in their thought processes, as
well as their support staff who work at City Hall. May each decision that is made honor you, and be for
the betterment of all of our citizens, and the guests who visit our beautiful city. This invocation I pray
in the name of our personal Savior and Lord. Amen.

49
Historians agree that this did not happen. There is no contemporaneous report to verify it and the original report is from
The Life of Washington, by Parson Mason Weems, who did not include the story until the 17
th
edition and also gave us the
myth of the cherry tree. See Edward G. Lengel, Inventing George Washington, 13, 22-23, 76-86 (Harper Collins Publishers,
2011).
43
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 6, 2009

May I ask you to bow your heart with me in prayer please? Our Heavenly Father, we bow our hearts
before you and the dignity of the City Council meeting. The Scriptures teach us, saying, "Blessed is the
nation whose God is the Lord."
50
We recognize that we are a nation under God. Our forefathers have
handed us the torch of faith; you alone have given us our freedom, our liberty, and our prosperity. And
faith in God is our heritage and our foundation. It was President George Washington who reminded us
that morality and faith are the pillars of our republic. But it is evident that these pillars are being eroded
in our secular and permissive society. Too long, we have neglected Your Word and ignored your laws.
We have tried to solve our problems without reference to you. Your Word is so clear, and is so simple.
For Your Word says: righteousness exalts a nation, but sin is a reproach and an embarrassment to any
people.
51
And so we confess to you our sins, and ask that we as a nation and as individuals, may
experience a moral and a spiritual restoration.

Our leaders in Washington D.C., and our leaders here in our beautiful city of Pismo Beach, often face
burdens and responsibilities, that at times, are overwhelming. And we ask tonight your divine guidance
and your power to rest mightily upon each of our leaders. In the moment of decision, give to them your
uncompromising courage to do what is morally right; with a cool head, and a warm heart. We pray
especially tonight for your divine understanding to rest strongly upon our intelligence community. And
we pause now to thank you for the two domestic Islamic terrorist plots upon our nation that had been
uncovered in recent days. Both of these would have inflicted severe damage to multitudes of our
citizens. And so tonight, we boldly declare our nation's motto; in God we trust. And not only is this
trust, this truth, engraved on our currency, but we also have enshrined it on our hearts and on our lips.
Surround us with your presence and power as we find our security from your promise, which says: I
will never leave you, I will never forsake you.

Tonight, may our mayor, her colleagues, and their support staff rest confidently in your ability to give
solutions to every problem they face; tonight and in the future. And may our united desire always be
that Your Word becomes our law, and Your Will becomes our chosen path. This we pray in the name
of him who Isaiah called the Prince of Peace,
52
our personal Savior and Lord. Amen.



50
Psalm 33:12
51
Proverbs 14:34
52
Isaiah 9:6 This is from the Old Testament, the belief that Jesus is the fulfillment of this prophecy is an exclusively
Christian idea, For to us a child is born, to us a son is given, and the government will be on his shoulders. And he will be
called Wonderful Counselor, Mighty God, Everlasting Father, Prince of Peace.
44
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 20, 2009

Will you please bow your heart with me in prayer? Our Heavenly Father, it was George Washington,
the first president of our great nation, who said, "It is the duty of all nations to acknowledge the
providence of Almighty God, to obey his will and to be grateful for his benefits, and to humbly implore
his protection and his favor." And then James Madison, the fourth president of our great nation, said,
"Before any man can be a member of civil society he must be considered a subject of the governor of
the universe." The founding leaders of our country believed wholeheartedly the words of Holy
Scripture
53
that are recorded in Psalm 33, "The word of the Lord is right. The earth is full of the
goodness of the Lord, and blessed is the nation whose God is the Lord."
54
Because of this legacy, left to
succeeding generations, we understand more fully why our U.S. Congress voted the model of our
nation to be: in God we trust. And as American citizens of this generation, we forthrightly proclaim: in
God we trust.

Cause us, Lord, to be ever mindful that no one is secure in their own accomplishments. Our positions
and our achievements never make us invincible. For God promises security and stability to those who
choose to put their confidence and their trust in him. And so may we always seem to live justly, and to
live righteously, and be zealous for the things that honor God. Thank you for each member of our City
Council, as well as their support staff. We would ask that you would infuse in them your wisdom and
your understanding. Give your solution to every difficulty and every need they face. We invoke your
irresistible presence and Your Will tonight, to become the resource that you graciously grant to each of
the elected leaders of our city. May proper decisions be made tonight, that will honor you and benefit
the citizens as well as the guests of our beautiful city. This invocation we pray in the name of our
personal Savior and Lord. Amen.



53
Completely unsubstantiated.
54
Verses 4, 5 and 12.

45
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

November 3, 2009

Our Heavenly Father, Wednesday, one week from tomorrow, is Veterans Day across our great nation,
and in our beloved city of Pismo Beach. And we pause in the dignity of this moment to offer thanks to
you for the privilege to be citizens of the greatest nation on earth: the United States of America. And
today, we lift loudly our voice in thanks for every military veteran who have proudly worn the uniform
of our nation, and served our great country at any cost. These 25 million men and women have
willingly fought any enemy, at great sacrifice, to guarantee to each citizen the right to life, liberty, and
the pursuit of happiness. Many of their comrades have paid willingly the supreme sacrifice, so that no
enemy and no oppressor shall remove from us the unalienable right of freedom. Many of our veterans
are hospitalized tonight, suffering loss of limb and body because of wounds they received on the
battlefield. To these, we pause tonight to say a sincere and heartfelt thank you. Allow your unseen, but
dynamic, presence to be near them and their families tonight. And cause each of us as citizens of our
great country to honor deeply in solemn appreciation, these millions of veterans across our great nation,
who live among us as friends and as neighbors.

And tonight, we give adherence to the wise instruction of our founding fathers. Let us not foolishly
trust in wealth, or power, or position, or pleasure, for time has taught us that these are only fleeting and
transitory, and so quickly fade away. So cause each of us to boldly proclaim: in God we trust. Today,
we pray earnestly for your wisdom to be desired greatly by President Obama, his advisers, and every
member of our Congress and Senate. We also pray for all of our servicemen and women serving our
country abroad and around the globe, especially in Iraq and Afghanistan; protect them with your eternal
power. And tonight we invoke your divine presence, so that it may fill our City Hall daily, as well as
our council chambers this evening. Give to each member of our City Council and their support staff
your wisdom and your understanding for matters at hand, today and in the future. God, bless America
protect our citizens here in Pismo Beach and the guests who visit our beautiful city. This invocation,
invoking your divine leadership continually, we pray in the name of our personal Savior and Lord.
Amen.
46
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

November 17, 2009

May I ask you to bow your heart with me in prayer please? Our Heavenly Father, Thursday of next
week has been proclaimed as Thanksgiving day, in our beloved nation. Thanksgiving day is America's
defining holiday. As individuals and as a nation, we are blessed above all of the people of the earth,
with food in abundance, family and friends. Thanksgiving day in 1986, present Ronald Reagan said,
"Perhaps no custom reveals our character as a nation so clearly as our celebration of Thanksgiving day.
Rooted deeply in our Judeo-Christian heritage, the practice of offering Thanksgiving underscores our
unshakable belief in God as the foundation of our nation, and our firm reliance upon Him from whom
all blessings flow." We join with our pilgrim fathers at their first harvest feast in 1621. They believed
and obeyed the words of Psalm 28:7, which says, "The Lord is my strength and my shield. My heart
trust in him, and I am helped, and I will give thanks to him."

Tonight, we remember and pray for the American military men and women around the world,
especially those serving in Iraq and Afghanistan, as they serve us with honor and bravery in places of
difficulty, danger, and challenge. May they sense our gratitude and your protection. We would
remember tonight to ask that you console the victims who survived the massacre at Fort Hood. May
your presence and comfort sustain the family members as they cope with the tragic loss of their loved
ones. Tonight we lift our hearts with gratitude, and boldly proclaim our nation's motto: in God we trust.
May our nation remain 'one nation under God', as President Abraham Lincoln coined the phrase in his
Gettysburg address November 19, 1863. And then said, "May we be one nation under God so that our
nation of the people, and our government, by the people and for the people, shall not perish from the
earth."

We are grateful for our freely elected mayor and council members. We undergird them and their
support staff with our words and our prayers daily.
55
We invoke your divine wisdom and courage to be
freely bestowed upon each of them, so that they may make good and right decisions. May each
determination bring esteem and righteousness toward God, and bring fairness and justice to each
citizen and guest in our city. Grant your protection and favor in abundance upon our civic leaders and
our citizens. Thank you for responding to this invocation of Thanksgiving, that we pray in the name of
our personal Savior and Lord. Amen.

55
1 Timothy 2:1-2.
47
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 1, 2009

Our Heavenly Father, Karl Marx, once said, "If we can remove history from people, then they can be
easily conquered. And we know that a bouquet of roses die when cut off from their roots."
56
So we
clearly understand that no liberty and no freedom is secure when our roots are removed. Those roots
that have been determined by God. For ethics, morals, and standards of behavior are determined by
God. Standards of behavior are not determined by a majority of people. So enable each of us to stand
firm for our godly convictions, understanding that it is an honor and a privilege to stand for right. May
the deep abiding sense of Gods holiness and Gods righteousness always determine our sense of right
and wrong. Tonight, once again, we strongly affirm our nation's motto: in God we trust. Help us to
maintain this firm conviction in our hearts as well as our lifestyles. For only then will we not be
helpless or defenseless as we face the future with confidence.

We thank you for the privilege of meeting together in this council meeting, conducted openly in public
for the benefit of our citizens. We ask that your invisible presence will fill our City Hall daily, as well
as our Council Chambers tonight. We pray for each of our council members, for these are our friends
whom we have freely elected to serve and to govern us. We pray for them publicly tonight, because we
pray for them by name daily in our private prayers. Grant that each of our City Council members, and
their support staff, and our mayor will be generously given your divine wisdom and your divine
guidance for the matters at hand tonight, and in the future. God, bless and protect America. Bless and
protect our president, and our military forces. Bless and protect the citizens of Pismo Beach, and the
guest to visit our beautiful city. We invoke your divine leadership tonight upon all who lead our city.
This invocation we pray in the name of our personal Savior and Lord. Amen.



56
No source can be located for this quote, it appears fictional.
48
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 15, 2009

May I ask you please to bow your heart in prayer? Our Heavenly Father, it's Christmas time in our city
and surrounding communities. Stores and shops are filled with carols and beautiful music of Christmas.
We thank you that so many have been prospered, that they may purchase gifts for those that we love
and are so dear to us. We ask you to allow your favor to rest upon our business community, who has
planned earnestly and worked diligently to sell their goods and services, and then sent sales tax and bed
tax to our city treasury. For your favor, we are grateful. Let us understand anew that the message of
Christmas is simple and wonderful. God wants to enter into all of life circumstances. And God chooses
a beginning point for his wonder workings in human beings; everyone is important. And so we pray
tonight for those families among us whose lives have been impacted by the economic slowdown.
Graciously provide for them as only you know how.

At this Christmas time, we also remember to pray for our military personnel as they serve the local
causes of freedom and liberty around the world. May each one who is deployed be safe and secure, and
may their loved ones have Gods comfort in presence, as families are separated one from the other.
When our next city Council meeting convenes, the Christmas lights will be out, the Christmas trees will
have faded, the Christmas ribbons will be forgotten, and Christmas cards will be packed away. But the
babe that was born in Bethlehem's manger will yet remain.
57
He will comfort when we are sorrowful,
he will provide meaning when life seems so useless and empty, he will bring light when the way seems
so dark, and he will provide joy when the circumstances are grim. And long after the carols were
hushed, and long after the gift certificates have been cashed, the babe that was born in Bethlehem's
manger will continue to bring happiness and satisfaction.
58
For His name is above all other names,
59

His reign is above all other rulers,
60
and His truth is above all other opinions.

And so tonight, we invoke your divine presence to so fill City Hall daily, and these council chambers
tonight, that you will give your wisdom to our mayor, and her colleagues, and their support staff, for
the matters at hand tonight and for the future as well. God, bless America. Protect our great country.
Protect the citizens in Pismo Beach, and protect the guests who visit our beautiful city. This invocation
we pray, this holy Christmas season, in the name of our personal Savior and Lord. Amen.



57
Luke 2:12.
58
Luke 2:12.
59
Philippians 2:9.
60
1 Timothy 6:15.

49
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
January 19, 2010
Will you please bow your heart in prayer with me? Our Heavenly Father, we stand on the threshold of
this new year, 2010. But already, our hearts have been deeply moved as we have listened to the news
reporters and viewed pictures of the devastating earthquake that has bought such havoc in the city of
Port-Au-Prince, the capital of Haiti. Many tens of thousands of citizens in this impoverished island
nation have been killed. Many more have lost what meager possessions they had. Great numbers of our
fellow Americans are freely giving cash and supplies to assist the Red Cross, and other relief
organizations, as they provide emergency food, and water, and clothing, and temporary shelter. We
continue daily to undergird these needy people in our earnest prayers, in this their time of desperation.
And we pray Lord that you will give them courage and give them strength as they face the seemingly
impossible road to recovery.
Chapter 40 of Isaiah in the Holy Scriptures records these encouraging words, "Have you not known?
Have you not heard? The everlasting God, the Lord, the Creator of the ends of the earth, he never
faints, nor is weary. And he gives power to the weak. And to those who have no might, he increases
strength. And our times of human weakness, God will enable us to meet every current difficulty by the
greatness of his might and by the strength of his power."
61
But Lord, cause us to never forget the need
for our devotion to God, and our obedience to his ways. We remember the prayer that was prayed by
President Theodore Roosevelt when he said, "We invoke the direction and the favor of Almighty God
for our guidance." And this is the stabilizing force that God provides for those who trust in him in these
uncertain times. And so again tonight we unitedly affirm our nation's motto: in God we trust.
In the dignity of this public City Council meeting, we invoke your wisdom to guide our elected mayor,
and her colleagues, and their support staff. May they make wise decisions that will honor God and
benefit our citizens. And with your Almighty help, and with your divine wisdom, we are confident that
every problem and every difficulty that confronts our City Council, and our city officials will find your
solution, and be properly resolved. Grant this, oh Lord. Thank you for hearing our united prayers. This
invocation we pray in the name of our wonderful Savior and Lord. Amen.
61
Verses are 21, 29 and 26, respectively.
50
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 2, 2010

Will you please bow your hearts with me in prayer? Our Heavenly Father, our U.S. Constitution gives
each of us the guarantee to the right to worship God at home, and at work, and at school. Our founding
fathers intended it thus to be. Benjamin Franklin proposed that the Constitutional Convention of 1787
begin each day with prayer.
62
George Washington had hoped that all nations would acknowledge the
providence of God, and obey his will. Thomas Jefferson warned the new United States to never forget
that their liberties are the gift of God. These are testimonies to the role of God in America's history.
And Abraham Lincoln later declared, "The sublime truth in the Holy Scriptures, and proven by all
history is; that nations only are blessed whose God is the Lord."

And Saint Luke admonishes us, "Grant that we may serve the Lord in holiness and righteousness, all
the days of our lives."
63
It was President Calvin Coolidge who said, "If American democracy is to
remain the greatest hope of humanity, it must continue abundantly in the faith of the Bible." And Isaiah
urges us to walk righteously, and speak uprightly.
64
This is the stabilizing force that God provides those
who trust in him, in certain times as well as uncertain times. You alone, oh God, give wisdom to the
wise, and knowledge to the discerning.
65


So we pray tonight, turn our hearts, and the hearts of our leaders toward you, and once again we boldly
affirm our nation's motto: in God we trust. Tonight, we would not forget to ask your guidance, and your
help, to all who give of their resources and their abilities to render aid and comfort to the tens of
thousands who suffer tonight, and seem so helpless in the little island nation of Haiti. And this because
of the result of the recent devastating earthquake. We invoke your presence and your favor to surround
our City Council. Grant your divine intervention as unitedly [sic] they seek solutions to the needs of
our beloved city. May our council, and their support staff, and all who work at City Hall, sense the
nearness of God in their offices and in their places of work as they serve our citizens and the guests
who come to our city. We ask your special favor upon our businesses who are finding it difficult
financially in these uncertain economic times. May we always determine to honor you and to benefit
each other. This invocation we pray, in the name of our personal Savior and Lord. Amen.




62
Again ignoring the conclusion, that the motion was so unimportant it was not voted on.
63
Luke 1:75
64
Isaiah 33:15
65
Daniel 2:21
51
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 16, 2010

Will you bow your heart with me in prayer please? We're grateful, Our Heavenly Father, to be citizens
of our great country, the United States of America. We acknowledge that your power and your blessing
has [sic] made us great. We enjoy blessings and benefits that are unknown by the vast majority of
earth's population. We have plenteous food, clean water, proper housing, and prosperity that abounds in
the lives of so many of our citizens. We accept these and many others as a direct result of the favor of
God. We confess that we do not deserve these benefits more than others, but we express thanks and our
desire to honor you in our daily lifestyles. With great appreciation, we boldly proclaim: in God we
trust.

Solomon, the wisest king who ever ruled, penned in the Holy Scriptures these words, "Righteousness
exalts the nation, but sin is a reproach and an embarrassment to any people."
66
And so tonight, we align
ourselves with the words of one of our great statesman, Daniel Webster. He served first as a U.S.
Senator and then as Secretary of State, and 150 years ago he declared, "If we abide by the principles
taught in the Holy Bible, our country will go on prospering and to prosper, but if we or our posterity
neglect the instructions and the authority of the Bible, no man can tell how suddenly catastrophe may
overwhelm us and bear all of our glory in profound obscurity."
67
So cause each of us to accept such
wise instruction personally, and make it a part of our lives and our lifestyles daily.

Tonight, in the dignity of this City Council meeting, we invoke your wisdom to guide our elected
mayor, and her colleagues, and their support staff. May they make wise decisions that will honor God,
and make better conditions for the citizens and the guests who visit our beautiful city of Pismo Beach.
Together with your almighty help, and your divine wisdom, we are convinced that every problem and
every difficulty that confronts our City Council will find your solution and be properly resolved. God,
grant this. Thank you for hearing our united prayers, this invocation we pray, in the blessed name of
our wonderful Savior and Lord. Amen.




66
Proverbs 14:34
67
This quote is inaccurate. The true quote does not mention the Holy Bible or the Bible at all. It does mention
religious institutions but only in conjunction with morality and our political constitution. The following is accurate:
if we maintain those institutions of government and that political union, exceeding all praise as much as it
exceeds all former examples of political associations, we may be sure of one thing, that, while our country
furnishes material for a thousand masters of the historic art, it will afford no topic for a Gibbon. It will have no
Decline and Fall. It will go on prospering and to prosper. But if we and our posterity reject religious institutions
and authority, violate the rules of eternal justice, trifle with the injunctions of morality, and recklessly destroy the
political constitution which holds us together, no man can tell how sudden a catastrophe may overwhelm us that
shall bury all our glory in profound obscurity. Should that catastrophe happen, let it have no history! Let the
horrible narrative never be written! Let its fate be like that of the lost books of Livy, which no human eye shall ever
read, or the missing Pleiad, of which no man can ever know more than that it is lost, and lost forever!
Daniel Webster, An Address Delivered before the New York Historical Society, February 23, 1852, available at
http://archive.org/stream/cu31924064123064#page/n5/mode/2up
52
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 2, 2010

Will you please bow your hearts with me in prayer? Our Heavenly Father, James Madison was the
principal author of U.S. Constitution. He was the father of our Bill of Rights. He was the fourth
President of the United States. It was he who said, "We have staked the whole fortune of American
civilization not upon the power of government, but far from it, for we have staked the future upon the
capacity of each and all of us to govern ourselves according to the 10 Commandments of God."
68
These
are fundamental expressions of Gods design for man, and to abandon our nation's moorings would be
absolutely tragic. And tonight, we join our hearts with our American founding fathers of the past,
whose vision and whose courage shape the future of our country. In true repentance, we ask you our
God, to protect and to preserve our beloved country. And cause our leaders to honor and follow you.
Grant to each of our leaders, nationally and locally, clear guidance and moral courage, as they make
decisions that directly influence our policies and our laws.

For it is recorded in Holy Scripture, and King Solomon declared it 930 B.C., God is a shield to those
who put their trust in him.
69
And again he said, He who trust in the Lord shall prosper.
70
And again
he said, Whoever trusts in the Lord shall be safe and secure.
71
And his father before him, King David
wrote, He that trust in the Lord, mercy shall surround him.
72
Our forefathers read and reread these
portions of Holy Scripture, and anchored their faith and their future to them. And as a result, in the year
1863 President Abraham Lincoln had this phrase engraved on every coin; in God we trust. And later
this phrase was authorized to be printed on each U.S. paper currency, and in 1956 the U.S. Congress
passed a resolution declaring our national motto: in God we trust. And Isaiah many years before wrote,
Anyone who trust in the Lord will not be disappointed.
73
And so tonight, we will boldly and firmly
affirm our nation's motto: in God we trust.

And it is in this spirit that we pray this invocation. We are so grateful that all of us can be a part of this
public City Council meeting. We invoke your blessings upon each council member. These are our
friends. We have freely elected them to serve us, and we pray for them daily. Cause each of them to
understand that they cannot properly discharge their responsibilities or their assigned task apart from
your enablement. Bless them and their support staff with the strength and the security of your invisible
presence, and grant to each of them your divine direction in their thought processes. For this will bring
proper solutions to each problem and each need that they encounter, and will benefit each citizen and
each guest in our beautiful city of Pismo Beach. This invocation we pray in the name of our personal
Savior and Lord. Amen.



68
This quote is false, or at least, falsely attributed to James Madison. David Barton is responsible for putting this quote into
Christian pop-culture.
69
Proverbs 30:5
70
Proverbs 28:25
71
Proverbs 29:25
72
Psalm 32:10
73
Isaiah 49:23
53
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 16, 2010

Our Heavenly father, America's founding fathers gave us a constitutional republic. Because of the
wisdom and the convictions of these righteous people, we are free today. But let us never forget that we
could die slaves if we lose sight and understanding of one basic truth; that is that freedom cannot exist
without morality. Immoral men and women cannot long endure, and will cease to exist. History is filled
with such examples. But character and moral fortitude is a requirement if we are to be able to govern
ourselves. Whenever morality and righteous lifestyles decline, the abuse of rights increases. To
abandon moral principles and to abandon righteousness, we will lose our freedoms. Our rights came
from God before any human government existed. And people joined together to form human
government in order to protect these rights, not to grant us rights, or to legislate out of existence these
inalienable rights. Make us men and women who are unintimidated, and who value moral righteousness
above public acclaim. It was George Washington, our first United States president who said, "It is
impossible to govern righteously without God and the Bible."
74


All 50 states in our United States without exception acknowledges God in their state constitution. In
1879, when California wrote its constitution, the preamble begins with these words, "We the people of
the state of California, are grateful to Almighty God for our freedom." Tonight, we feel much like Pres.
William McKinley, our 25th president, who declared in his 1897 inaugural address, "I assume this
responsible duty, as President of the United States, relying on the support of my countrymen and
invoking the guidance of Almighty God."

And so, in this public Council meeting tonight, we invoke the wisdom and the guidance of Almighty
God to illuminate the thought processes of each of our City Council members. We have freely elected
them to govern us, and we pray for them daily. Help each of them, our mayor, her colleagues, and their
support staff, as they endeavor to make wise decisions. And since you transmit your blessing and your
favors through headship, allow your favor to flow from City Hall and these Council chambers to every
home and to every citizen who resides in our city and to each guest who visits our city. Cause our
beautiful city of Pismo Beach, that borders the blue Pacific, to become a better place to live and to
enjoy life. This invocation we pray in the name of our personal Savior and Lord. Amen.

74
This is not accurate. There is no evidence recording that Washington said or wrote such a statement.
54
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 6, 2010

Will you bow your hearts in prayer please? Our Heavenly Father, we lift our hearts in gratitude tonight,
that we are privileged to participate in our public City Council meeting. We offer praise to God, for
your continued protection over our nation and our city. And we pray that your omniscience and your
knowledge will be granted to our intelligence community, as they continue to safeguard our country
and our citizens. May no further terrorist plots be carried out, and may any plans made to do us harm be
uncovered and defused before they can be realized. Cause righteousness to reign in our lives
individually and in our government. It was President Herbert Hoover, our 31st president, who said,
"Where there is a lack of honor in government, the morals of the whole people are poisoned. There is
no such thing as no man's land between honesty and dishonesty. Our strength lies in spiritual concepts;
it lies in public sensitivity to evil." Then he said, "Our greatest dangers are not from invasion by foreign
armies, but rather that we commit suicide from within, by complaisance with evil or public tolerance of
scandalous behavior." The power of prayer is a dynamic force that repels unrighteousness, but the
influence of prayer has been dramatically reduced in our public life. And the moral compass of the
Holy Scriptures has been largely laid aside. Public morality is declining to dangerously low points. So
help each of us to always seek to live justly, and to pursue righteousness, and to be zealous for a
lifestyle that honors God. We are most grateful for our nation's motto that so strongly instructs us: in
God we trust.

Thank you for every member of our City Council and their support staff. Infuse in them your wisdom
and your understanding. Give to them your solution to every difficulty that they face. We invoke your
irresistible presence and will tonight to become the resource that you graciously grant to each of the
leaders of our city. May proper decisions be made tonight that will honor you and that will benefit the
citizens and the guests of our beautiful city. This invocation we pray in the name of our personal Savior
and Lord. Amen.
55
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 20, 2010

Will you please bow your heart with me in prayer? Our Heavenly Father, it was June 28, 1787 that
Governor Benjamin Franklin of Pennsylvania hosted the 55 delegates in Pennsylvania to the first
Constitutional Convention. He said, "I've lived a long time, and the longer I live, the more convincing
proofs I see of this truth; that God governs in the affairs of men. If a sparrow cannot fall to the ground
without Gods notice, is it probable that an empire can rise without his aid? We have been assured in
the sacred writings that except the Lord build this house, they labor in vain who build it. Without his
concurring aid, we shall succeed in building this Republic no better than the builders of Babel. I
therefore move, that henceforth, prayers imploring the assistance of Heaven and its blessings on our
deliberations be held in this assembly every morning before we proceed to business, and that one or
more of the clergy of this city be requested to officiate in that service." James Madison concurred, and
such resolution was passed.
75
And from that day until today, for the past 223 years, prayers of have
opened both houses of our Congress daily; in the U.S. Senate, and US House of Representatives.

And so it is in this spirit we pray this invocation tonight. We are grateful for the privilege to gather
publicly in this Pismo Beach City Council meeting. This is the last Council meeting before Randy
Bloom retires as our City Director of Community Development. Thank you for his leadership in our
cities these past 10 1/2 years, and all that has been accomplished through his leadership. Our city is a
better place for our citizens and our guests because he has served us with his skills. We have freely
elected our mayor and her colleagues to our City Council, and in obedience to Holy Scripture, we
support, and we undergird them and their staff with our prayers.
76
We pray for them tonight publicly, as
we have prayed for each of them by name in our personal prayers. We are reminded again that good
government is not the idea that was generated in the heart of people, but good government is the
principal that originated in the heart of God. So give to each of our Council persons tonight your divine
wisdom to make good decisions, and grant that each decision will honor God, and be for the betterment
of all the citizens of Pismo Beach and all the guests who visit our beautiful city. We thank you for
hearing our prayer. For this invocation we pray in the name of our personal Savior and Lord. Amen.

75
As pointed out previously, this is false. The motion was not even voted on, let alone passed.
76
1 Timothy 2:1-2.
56
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 4, 2010

Our Heavenly Father, we pause to offer our heartfelt thanks, giving that you have again extended your
protection to our citizens and our nation this past 24 hours. Thank you that the would-be terrorist, who
plotted to blow up a car and kill scores and scores of citizens in New York City, has failed in his
attempt and was arrested, and now awaits trial. Continue to grant your favor to our intelligence
community, as they seek to guard our nation against all those, foreign and domestic, who would
terrorize and harm our citizens. It was 1789, President George Washington said, "It is the duty of all
nations to acknowledge the providence of Almighty God, to obey his will, and to be grateful for his
benefit, and to humbly implore Gods protection and favor." When Nehemiah was mayor of Jerusalem,
the Bible says of his brother Hanani, that he was a faithful man and honored God more than many.
77

The Bible and history unite and continually teach us that Gods favor accompanies righteousness. For
those who practice righteousness shine as beacons of light. And such righteousness brings Gods
blessings, and his protection.

Cause each member of our City Council to humbly seek the blessing and favors of God, that they may
properly discharge their responsibilities and the tasks that have been assigned to them. And as a result,
may righteousness flow from City Hall, and may righteousness flow from these council chambers, into
each home in our beautiful city and into the lives of each of our citizens. Thank you for your continued
protection and provisions for our city and its citizens. We are grateful for these open council meetings,
and this one tonight, where all may participate in the affairs of our city. Bless all who work at City
Hall. Cause them to serve and to sense the strength and the security of your enabling presence. Grant
our city Council and their support staff your divine direction in their thought processes, and may they
receive your solution for each of the problems and needs that they may encounter tonight. May each
decision honor you, and benefit the citizens and the guest of our beautiful city. This invocation we pray
in the name of our personal Savior and Lord. Amen.



77
The Bible says that Nehemiah put Hanani in charge because he feared God more than most men do. Nehemiah 7:2.
57
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 18, 2010

Will you bow your heart with me in prayer please? Our Heavenly Father, our nation was founded on
principles of righteousness by men and women who both knew and loved God. The Pennsylvania State
Assembly, in 1751, called for the forging of a bell to commemorate William Penn's original state
charter. The legislators included the instructions that a scripture verse from the Holy Bible be inscribed
on that bell. And the verse chosen was Leviticus 25:10, "Proclaim liberty throughout all the land, and
unto all the inhabitants."
78
Our founding fathers considered important for all generations to know that
God is the source of true freedom. So help us to understand, as did our founding fathers, that
righteousness does not just happen by accident, but righteousness must be pursued. We refuse to be
absorbed by the uncertainty in the daily headlines. The good news is: no one is helpless in the face of
the future. Our daily prayer seeking Gods blessing and Gods protection are our greatest shield from
any danger or threat that we may face. It was John Jay, our first United States Supreme Court Chief
Justice, who said, "Rely upon the good providence of Almighty God for success, in full confidence that
without his blessing, all our efforts will inevitably fail." Today, as a nation and as individuals, we are
neither ashamed nor embarrassed to let the world know that we indeed boldly affirm our nation's
motto: in God we trust.

And it is in this spirit that we pray this invocation. In heartfelt humility we implore your protection and
your favors. We invoke your infinite wisdom to be graciously bestowed upon the members of our City
Council. The problems our city faces are known by our council members, but more importantly, they
are known by you, oh God. So grant solutions that will honor you, and be for the betterment of each
citizen and each guest who visits our city. We have freely elected five citizens, our friends, to serve as
council members to lead our beautiful city. May your leadership be manifest in their lives and in their
decisions, as well as their support staff. Where there may be confusion, bring harmony. Give your
wisdom for the proper answer and the proper solution. We pray tonight you would fill City Hall and
these council chambers with the peace and the power of your eternal presence, and cause each home
and each citizen in Pismo Beach to feel the impact of your eternal presence. This invocation we pray in
the name of our personal Savior and Lord. Amen.

78
The full text, with contextual passages (25:1, 8-12), reads:
The LORD then spoke to Moses at Mount Sinai sayingYou are also to count off seven Sabbaths of years for
yourself, seven times seven years, so that you have the time of the seven Sabbaths of years, namely, forty-nine
years. You shall then sound a rams horn abroad on the tenth day of the seventh month; on the Day of Atonement
you shall sound a horn all through your land. You shall thus consecrate the fiftieth year and proclaim a release
through the land to all its inhabitants. It shall be a jubilee for you, and each of you shall return to his own property,
and each of you shall return to his family. You shall have the fiftieth year as a jubilee; you shall not sow, nor reap
its aftergrowth, nor gather in from its untrimmed vines. For it is a jubilee; it shall be holy to you. You shall eat its
crops out of the field.

58
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 1, 2010
(Dr. Paul Toms)

Will you join me please in a moment of prayer? Eternal God, our Heavenly Father, we come to you at
the end of a busy day, all kinds of activities and challenges, opportunities. We give you thanks for your
provision, for your guidance, for your watchful care over us. Now we come to you again to seek your
blessing upon us in this special meeting. Thankful for where we live, thankful for the blessings we
enjoy here, we seek your blessing today upon this meeting in a special way. Bless members of this
council. Bless these other elected and appointed officials. We thank you for what they do for us. Thank
you for their commitment to that which is desirable, and useful, proper, and right. May the blessing of
God rest upon us, and upon our community, for which we pray; we pray for the people who live here,
we pray for the people who visit here, we pray for the people who come from here who are overseas,
and some of them fighting in very difficult places. Watch over them, protect them, help them, bring an
end to these conflicts, and return them safely home. Thank you for the people to watch over us here; for
our policeman, policewomen, fire department people, for other people who work and succeed in doing
so many things that make life comfortable and far more easy for us. So we give you thanks today, we
pray your blessing upon this meeting. We ask for your inspiration, we ask it will be led by you. We
thank you that these people are seeking to do the right thing. The Bible says that if we lack wisdom, let
us ask of God.
79
So we ask of you today to give wisdom, and guidance, and direction. Help us as we
commend ourselves into your loving care. We pray all these things in the name of the Great Redeemer,
your Divine Son, amen.




79
James 1:2, 3, 5 - Consider it pure joy, my brothers and sisters,

whenever you face trials of many kinds, because you
know that the testing of your faith produces perseverance. If any of you lacks wisdom, you should ask God, who gives
generously to all without finding fault, and it will be given to you.
59
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 15, 2010

Will you bow your heart with me in prayer? Our Heavenly Father, history teaches each of us that when
the capitol building was built in Washington D.C., the designers were well aware of the dependence of
the members of Congress upon God and prayer. The eighty third Congress designated a room in the
rotunda that is always open for private prayer and meditation for the members of Congress, whenever
Congress is in session. This prayer chapel stands as a witness to the need for prayer by our nation's
leaders. In the focal point of the room is a stained glass window that depicts General George
Washington, kneeling in prayer.
80
Surrounding him are the words found in Psalm Chapter 16,
Preserve me, oh God, for in thee, do I put my trust.
81
When our pilgrim fathers came to this new
world, they came in search for religious freedom. The faith and the prayers of our founding fathers
made us truly one nation under God. Faith in God has played an integral role in the founding and the
growth of our great nation. One of the most important characteristics of our country is our legacy of
faith and trust in God. So again, we here tonight boldly affirm our nation's motto: in God we trust. And
it is in this spirit that we pray this invocation tonight.

We are grateful for the privilege to gather publicly in the Pismo Beach City Council meeting. We have
freely elected our friends, the mayor and her colleagues, to our City Council to serve us. And in
obedience to Holy Scripture, we support them and undergird their support staff with our prayers.
82
We
pray for them corporately tonight, as we pray for each of them daily by name in our personal prayers.
And we understand that good government is a principle that originated in the heart of God. So tonight,
cause each of our council members to sense the power of your invisible presence, and we invoke your
divine wisdom and your courage be given to each of them to make good and right decisions. Grant that
each decision will honor God, and be for the betterment of all citizens of Pismo Beach, and the guests
who visit our beautiful city. We thank you for hearing and responding to our prayer. This invocation
we pray in the name of our personal Savior and Lord. Amen.









80
Although the window may exist, the event portrayed did not happen.
81
Psalm 16:1-1 Keep me safe, my God, for in you I take refuge. I say to the Lord, You are my Lord; apart from you I
have no good thing. I say of the holy people who are in the land, they are the noble ones in whom is all my delight. Those
who run after other gods will suffer more and more. I will not pour out libations of blood to such gods or take up their
names on my lips.
82
1 Timothy 2:1-2.
60
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

July 6, 2010

Would you please bow your heart with me in prayer? Our Heavenly Father, two days ago, Sunday, July
4, the citizens of our great nation celebrated our freedom as a nation our 234
th
birthday. It was July
4
th
, 1776 that John Hancock, President of the Continental Congress led the elected representatives of
the thirteen colonies to vote on a resolution declaring their independence from Great Britain. This
document, written by Thomas Jefferson, our Declaration of Independence was officially ratified
causing the thirteen colonies of America to become the United States of America. In its opening
statement, it reads: All men are created equal, they are endowed by their Creator with certain
unalienable rights., that among these are life, liberty, and the pursuit of happiness.
83


The representatives at the Continental Congress proclaimed themselves to be free and independent with
a firm reliance on the protection of Divine Providence. Little wonder then, that the United States
Congress in 1956, under the leadership of President Dwight Eisenhower passed a resolution declaring
our national motto to be: In God, We Trust. And it was President Ronald Reagan on August 23, 1984
who said, Without God, there is no virtue, because there is no prompting of the conscience. Without
God, there is a coarsening of our society. And without God, democracy will not, and cannot, long
endure. He concluded by saying, If we ever forget that we are one nation, under God, then we will be
nation gone under.

So tonight, help us and our generation to never forget the godly principles and the values upon which
our great nation was founded. We pray for our mayor, for the members of our City Council, and their
support staff. Tonight, we invoke Gods divine wisdom and courage to be freely given to each of the
members of our City Council. May each determination that is made bring esteem and righteousness
toward God, and at the same time bring justice and fairness and worth to each citizen, and each guest
visiting our beautiful city. May your protection, and your favor and abundance, be upon our leaders and
our citizens. Thank you for hearing and responding to this prayer of invocation. We pray it, in the name
of our personal Savior and Lord. Amen.



83
The full opening reads: When in the Course of human events, it becomes necessary for one people to dissolve the
political bands which have connected them with another, and to assume among the powers of the earth, the separate and
equal station to which the Laws of Nature and of Natures God entitle them, a decent respect to the opinions of mankind
requires that they should declare the causes which impel them to the separation.

We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain
unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
August 3, 2010
Will you bow your heart with me in prayer, please? Our Heavenly Father, it was President George
Washington who on one occasion said, It is impossible to govern the world without God and the
Bible.
84
In 1864, during the Civil War, the United States Congress approved engraving the phrase In
God, We Trust on the two cent coin. Forty-four years later, in 1908, legislation was passed to engrave
In God, We Trust on all U.S. coins. And forty-seven years later, in 1955, when President Eisenhower
was our President, Congress passed a resolution that In God, We Trust would be printed on all coins
and all U.S. currency. One year later, in 1956, the phrase In God, We Trust became the national
motto of our great country. And tonight, as American citizens, we boldly affirm as a nation, and as
individual citizens In God, We Trust. And it is in this spirit that we pray this invocation tonight.
As American citizens living in this great nation, we enjoy the blessings of freedom that have been
given to us by God. As such, we join our voices with President Warren G. Harding, who once said, I
implore the favor and the guidance of God in heaven.
Bless all who work and serve us in our City Hall. Cause them to sense the strength and the security of
your invisible presence. Bless our City Council whom we have freely elected. These are our friends, for
whom we pray daily. May the members of our City Council understand that they cannot properly
discharge their responsibilities, or the tasks assigned to them, without your help. Tonight, crown this
City Council with your nearness, and give your divine guidance and your divine direction in their
thought processes. May each decision that is made honor you and be for the betterment of all of our
citizens , and the guests who visit our beautiful city. This invocation we pray, in the name of our
personal Savior and Lord . . . Amen.
84
This is not accurate. There is no evidence recording that Washington said or wrote such a statement.
62
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 17, 2010
(Father Victor Abegg)

We pause for a moment to open our hearts and our minds so as to allow the great force of our world
that we all recognize in so many different ways, to enter into our lives, to help us be transformed this
evening, and to truly help us to derive the wisdom that we need in order to come together for the sake
of the needs of the community of Pismo Beach. May all that we know and all that we hold dear come
together for the sake of the common good. May we be blessed with wisdom. May we search for a true
understanding of what is being said by one another, so that we may come to a consensus and draw
ourselves in to a one-ness which leads to the establishment of a more remarkable union as far as our
citizens are concerned and as far as our work is concerned. May we all be blessed then, to listen
carefully, to understand deeply, and to reflect powerfully, on what is the best. To allow our minds to be
changed if they need to be changed, and to allow our hearts to reach out where they need to reach out.
May we ask all of this and be guided by all of this, in the name of the one whom each of us holds dear,
the one that we call Lord, and make this prayer. Amen.


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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 7, 2010

Will you bow your heart with me in prayer? Our Heavenly Father, our nation was founded on Biblical
principles by men and women who knew and honored you. The Pennsylvania State Assembly in 1751
called for the forging of a bell to commemorate William Penns original state charter. And then
legislators included instructions that required a verse from the Bible to be inscribed on the bell and the
verse chosen was recorded in Leviticus chapter 25, verse 10: Proclaim liberty through all the land,
unto all the inhabitants.

Our Founding Fathers considered it important for all generations to know that God is the source of our
freedoms. It was on June the 14
th
, 1954 that President Dwight D. Eisenhower signed a joint resolution
which added the phrase under god to the pledge of allegiance to our flag, and then he said, In this
way we are re-affirming our religious faith in America's heritage and our future. And in this way we
constantly strengthen those spiritual weapons that forever will be our country's most powerful resource
in peace and in war.

So tonight, we bow our hearts and our heads to acknowledge your divine providence. We desire to do
Your Will. We are most grateful for all of your benefits to us: life and health and friends and your
divine presence and our beautiful city. Make us mindful of the words of King Solomon who said,
Righteousness exalts a nation, but sin is a reproach and an embarrassment to any people.
85
And
heartfelt humility compels each of us to repent of our sins as we implore your protection and your
continued favors. Allow your infinite wisdom to be graciously bestowed on our City Council. The
problems our City Council faces today are known by our Council members but, more importantly, they
are also known by you, our God, and we ask that you would grant solutions that will honor you and
benefit each citizen. We have freely elected these five citizens, our friends, to lead our city. May your
leadership be manifested in their lives, and in their decisions, as well as the staff that supports them.
Where there may be confusion, bring harmony. And where there may be seemingly no solution, give
your wisdom for the proper answer. We ask that City Hall and these Council chambers will be filled
with the peace and power of your eternal presence, and cause each home and each citizen in Pismo
Beach to feel the impact of your eternal presence. This invocation we pray, in the name of our personal
Savior and Lord . . . Amen.



85
Proverbs 14:34
64
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 21, 2010

Our Heavenly Father, tonight in this regular meeting of the Pismo Beach City Council, we are
reminded of the words of President Abraham Lincoln, declared a hundred and forty-seven years ago,
on March 30, 1863. Our nation at that time was in the midst of the Civil War, and President Lincoln
said, Whereas it is the duty of nations, as well as men, to owe their dependence upon the overruling
power of God, and to confess their sins and transgressions in humble sorrow, yet with assured hope that
genuine repentance will lead to mercy and pardon and to recognize his sublime truth that has been
announced in the Holy Scriptures, and proven by all history, that those nations only are blessed whose
God is the Lord.

It is in this spirit that we pray this invocation tonight. We join with hundreds of communities across our
land, as we salute and honor our brave military youth and veterans of the conflict in the Middle East.
These young men and women have strongly believed, and taught us by their lives and their courage and
their actions that liberty is dearly bought, it is difficult to keep, and liberty must be continually paid for.
These youth have offered their most vital years of youth in service to our country, in our Army and
Navy, in our Coast Guard and Marines and Air Force. Shower your wisdom upon our President, and
upon all of our national leaders as they seek you tonight.

Bless our City Council. These are our friends whom we have freely elected, for whom we pray daily.
Help them as they earnestly endeavor to make Pismo Beach a better place for us to live and enjoy life.
Crown this Council meeting with the nearness of your presence, and give your divine guidance in their
thought processes. May each decision that is made honor you and be for the betterment of all of our
citizens, and the guests who visit our beautiful city. This invocation we pray, in the name of our
personal Savior and Lord . . . Amen.


65
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 5, 2010

Will you bow your heart with me in prayer, please? Our Heavenly Father, our American history teach
us that it was October 3
rd
, 1789, that's just two hundred and twenty-one years ago last Sunday, that
President George Washington gave us these immortal words, when he said, and I quote It is the duty
of nations to acknowledge the providence of almighty God, to obey his will, and to be grateful for his
benefits, and to humbly implore his protection and his favor. We are exceedingly grateful for the
bounty of heaven, that has preserved our nation and our community.

Today we enjoy peace and prosperity, and wealth and power that is unknown by any other people on
Earth. And tonight as we enjoy your gracious and guiding hand, we do so in our land and our beautiful
city of Pismo Beach. We invoke Gods blessing upon our mayor and the members of our City Council.
We have freely elected these, our fellow citizens, and we pray for them daily. Our City Council and
their support staff seek earnestly to make Pismo Beach a better place to live and to enjoy life with our
families and with our friends. We would pray tonight that you would allow for the power of your
eternal presence to cause their thought processes to respond to your divine guidance. May the decisions
that are made honor you and be for the betterment of Pismo Beach, for all of our citizens, and the
guests who visit our beautiful city. This invocation we pray, in the name of our personal Savior and
Lord . . . Amen.


66
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 19, 2010

Will you bow your heart with me in prayer? Our Heavenly Father, George Washington, the first
President of our country, said, It is the duty of all nations to acknowledge the providence of almighty
God, to obey his will, and to be grateful for his benefits, and to humbly implore his protection and his
favor. And James Madison, our fourth President, said, Before any man can be a member of civil
society, he must be considered as a subject of the governor of the universe. The Founding Fathers of
our country believed wholeheartedly in what these men said and the words of Holy Scripture that are
revealed in Psalm 33, which says, The Word of the Lord is right The Earth is full of the goodness of
the Lord Blessed is the nation whose God is the Lord.
86
And because of this legacy that was left to
succeeding generations, we understand more fully why our Congress voted the motto of our nation to
be, In God, We Trust. As American citizens of this generation, we proclaim forthrightly, In God,
We Trust.

Cause us Lord to be ever mindful that no one is secure in their own accomplishments. Our positions
and our achievements never make us invincible. God promises security and stability to those who
choose to put their trust in and their confidence in him. May we always seek to live justly and
righteously and be zealous for the things that honor God.

Thank you for each member of our City Council, and their support staff. Infuse in them your wisdom
and your understanding. Give each solution to every difficulty and need that they face. We invoke
your irresistible presence and will tonight to become the resource that you so graciously grant to each
of the elected leaders of our city. May proper decisions be made tonight, that will honor you and
benefit the citizens of Pismo Beach, and the guests of our city. This invocation we pray, in the name of
our personal Savior and Lord. Amen.





86
Psalm 33:4-12 reads:
For the word of the Lord is right; and all his works are done in truth. He loveth righteousness and judgment: the earth is full
of the goodness of the Lord. By the word of the Lord were the heavens made; and all the host of them by the breath of his
mouth. He gathereth the waters of the sea together as an heap: he layeth up the depth in storehouses. Let all the earth fear
the Lord: let all the inhabitants of the world stand in awe of him. For he spake, and it was done; he commanded, and it
stood fast. The Lord bringeth the counsel of the heathen to nought: he maketh the devices of the people of none effect. The
counsel of the Lord standeth for ever, the thoughts of his heart to all generations. Blessed is the nation whose God is the
Lord; and the people whom he hath chosen for his own inheritance.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

November 16, 2010

Will you please bow your heart with me in prayer? Our Heavenly Father, Karl Marx once said, If we
can rip way history from any people, they will be easily conquered.
87
We have learned that a bouquet
of beautiful roses soon die because they are cut off from their roots. Ethics and moral standards of
behavior are not to be determined by a majority of people, but by God himself. For it was Harry
Truman, our President, who said, The fundamental basics of this nation's laws was given to Moses on
Mt. Sinai, and the fundamental basis of our Bill of Rights comes from the teachings of Exodus, Isaiah,
Matthew and St. Paul.

So let none of us believe the misconception that freedom is a license to sin or go our own way or do as
we wish, but rather help us to understand that freedom is the responsibility and the power to do what is
right. No liberty is secure when it is removed from the roots that have been established by God. Our
U.S. Constitution was written by moral people, it was written for moral people and it will work for no
other people. Our forefathers conceived freedom in their hearts, and wrote freedom on our documents,
and yet freedom is not free. Our freedoms cannot survive without our personal responsibility and
courage and they certainly cannot survive without our eternal vigilance.

So help each of our civic leaders, and help each of us as citizens to stand firm. Let us never be
intimidated by numbers, but cause us to be men and women of conviction who value moral
righteousness above public acclaim. Grant the light of your irresistible presence to avail, so that no
unrighteousness can prevail. As loyal citizens, tonight we boldly proclaim our nation's motto, In God,
We Trust.

We invoke your favor upon our city of Pismo Beach, as we forsake and confess our sins. Release your
blessings upon each of us as citizens, and all who work at City Hall and serve our community. Give
your eternal wisdom to our friends, whom we have freely elected to serve on the City Council, for these
we pray daily by name. Help them as they endeavor to make Pismo Beach a better place to live and to
enjoy life. Especially this evening, give your divine guidance to our mayor, each council member and
their support staff. This invocation we pray, in the name of our personal Savior and Lord . . . Amen.



87
No source can be located for this quote, it appears fictional.
68
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 7, 2010

Will you please bow your heart with me in prayer? Our Heavenly Father, we thank you for each
member of our City Council, who has served our city and our citizens so well. You have graciously
given us Mary Ann Reese, six years ago as your gift to us, as our mayor. She has led our Council with
skill and dignity even when difficult decisions had to be made. It has been rewarding to see each
member of our council work together in such a great spirit of unity, though each decision has not been
unanimous.

The Bible speaks of leadership as quote, serving with one accord.
88
We have seen this attitude
modeled before us regularly. You have graced each of our council members with understanding and
courage, yet with a spirit of meekness. They have demonstrated that meekness is not weakness, but
meekness is strength and skills under control. And tonight, our newly elected mayor, Shelly
Higginbotham, will be duly installed. We believe she is your gift to us, for this season, to help guide
our city and this council through somewhat difficult financial times.

We offer you gratitude for our council and their support staff, who have shown wisdom and soundness
of mind. They have led with integrity and transparency, and have made character a high honor. May
they always remain calm and controlled, manifesting uprightness and righteousness. For such
leadership shall help keep our city strong as we enter the new year of 2011. Let there never be division
or confusion, but may your unseen irresistible presence caused their united efforts to be structured,
efficient and productive. We pray the prayer of President Theodore Roosevelt, when he said and I
quote, We invoke the direction and the favor of Almighty God for our guidance.
89
And so tonight,
Our Father, we affirm again to you our nation's motto, In God, We Trust.

May your nearness always hallow these council chambers, and cause each decision that is made to
honor you and to make Pismo Beach a better place to live and to enjoy life. We ask each of these
benefits to our city, for all of us who live in it, and for the visitors who come to visit us. We ask this
invocation in the wonderful name of our personal Savior and Lord. Amen.



88
Romans 15:5-6 NASB: Now may the God who gives perseverance and encouragement grant you to be of the same mind
with one another according to Christ Jesus, [6] so that with one accord you may with one voice glorify the God and Father
of our Lord Jesus Christ.

89
There is nothing in the historical record to support this quote attributed to T. Roosevelt.
69
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 21, 2010
(recording partially missing)

. . . will become a reality in the Middle East, in Iraq and Afghanistan, in Iran and on the Korean
Peninsula. In the truest sense, let earth receive her king, for the message of Christmas is evident in the
lives of our citizens throughout Pismo Beach. In many of our stores, and especially the outlet center,
favorite Christmas carols are heard such as, Silent Night, Oh Come All, Ye Faithful and Joy to the
World, the Lord Has Come. These carols fill the air, and they fill our hearts, and Christmas teaches us
that God is able and willing to bring life to the most barren settings, and that he is able to breathe hope
into the most unpromising situations, and all of life's circumstances for each of us today.

We thank you for your many gifts to us and to our city this Christmas season. Thank you for the
numerous inches of rain that have fallen in our area, making our hills and our countryside lush and
green. Thank you for our new mayor, Shelly Higginbotham, and our new mayor pro-tem Chris Vardas,
and our united city council and their grand support staff. We would invite your guidance through their
skills and their talents as they dedicate them to make Pismo Beach a better place, and a better place to
live in 2011. This invocation we pray in the name of our personal Savior and Lord. Amen.


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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

January 18, 2011

Will you bow your heart with me in prayer, please? Our Heavenly Father, General George Washington
emerged as the most significant leader in the founding of our United States. History has esteemed him
as the father of our country. He was surrounded by a host of courageous leaders, brilliant thinkers,
passionate orators, many better educated than he. Washington possessed energy, vision and calm
demeanor, but the reason cited for his emergence as the supreme leader in the early days of our country
was because of his high moral character his sterling character, combined with his leadership genius.
He could be trusted implicitly. Thomas Jefferson wrote of George Washington, His integrity was most
pure. His justice was most inflexible, and no motives of friendship or hatred were able to bias his
decisions. He could lead over a long period of time. He could lead in extraordinary difficulties. He led
our trips to victory in the Revolutionary War. He superintended the Constitutional Convention. He was
elected unanimously as our first United States President.

So, oh God, cause each of us to strive for such character and such righteousness in our lives, and in our
decisions. May our nation, and may our community, be strengthened morally by such actions. In this
first public City Council meeting of this new year, and this new decade, may each Council member,
each staff member, each community leader and each citizen determine to have a positive influence as
we dedicate ourselves to lifestyles of character and righteousness. We are most grateful for our new
mayor, Shelly Higginbotham, whom you have given to us, as well as her colleagues on our current City
Council. We invoke your wisdom, and your understanding to be graciously bestowed in their thought
processes. May each decision bring honor to God, and benefit our citizens.

We continue to remember in our prayers our fellow American citizens in Tuscon, Arizona and
especially those who have lost loved ones, and grieve tonight because of a senseless tragedy. Cause
each of those who were injured to be granted a speedy and a complete recovery. Our father, accept our
gratitude for your continued protection to our community, and to each citizen and each guest that visits
our city. This invocation we pray, in the name of our personal Savior and Lord . . . Amen.


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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 1, 2011

Will you bow your hearts with me in prayer? Our Heavenly Father, we bow our hearts before you in
humility. We ask you to unite our hearts and strengthen our hands, to work together for the good of our
nation, for our state and for our community. It was Horace Greeley, a respected 19
th
century newspaper
editor, who reminds us in our quote, Our founding fathers emphasized that liberty cannot be
established without morality, nor can morality be established without faith. Success depends upon
Gods word being in our hearts, and our minds, and upon our lips.

America was founded upon principles recorded in the Holy Scriptures. Our founders left us an
abundance of quotations in their personal correspondence, as well as their public statements, and these
show us the profound extent to which their thinking and their lives were influenced from a righteous
worldview. They thought, and they reasoned, from a Biblical perspective. This greatly shaped and
determined their political ideals for our Republic.

We pray for our President tonight, for the House and Senate leadership, and for all those who are
seeking to bring peace and justice to our dangerous and troubled world. We pray especially for the
citizens of Egypt in their current struggle. Allow your protection to surround all those who serve in our
armed forces around the world. Thank you for their commitment to defend our freedoms even at the
cost of their own lives. Be near to their families, and assure them of your love and your concern for
them.

We confess our need of you, and your invisible presence, in this council meeting tonight. For you alone
know our future, and only you can bring the strength and the wisdom to our mayor, her colleagues, and
their support staff, to meet the challenges, as well as the opportunities, that we face as a city. We invite
your blessings upon our city, upon each citizen and each guest who visits our city. And we thank you
for friends as well as fellowship. This invocation we pray, in the wonderful name of our Savior and
Lord . . . Amen.


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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 15, 2011

Will you bow your heart with me in prayer, please? Our Heavenly Father, our world has looked
intently for eighteen days as millions of Egyptian citizens have protested in the streets of Cairo, their
capital city, and other large cities in their country. They are protesting thirty years of tyrannical reign of
the ruthless dictator of this country, Egypt. Eighty million Egyptians believe as our forefathers believed
that freedom and liberty does not come from government, but rather it comes from our creator, and
since the resignation and departure of their dictator days of jubilation have followed, and we pray that
peace and goodwill may be enjoyed now by all the citizens of Egypt. May any who would deny such
freedom be thwarted by your divine intervention.

We are most grateful for your blessings upon the founders of our beloved country, the United States of
America. You have honored their vision for the days they lived, as well as for the 234 years that have
followed. And today, we pray the prayer that was written by Samuel Smith, who was a student at
Andover University Theological Seminary in 1831, he wrote, Let music swell the breeze and ring
from all the trees. Sweet music, freedom's song. Let mortal tongues awake. Let all that breathe partake.
Let rocks their silence break. This song, prolong. Our father's God to thee, author of liberty, to thee we
sing. Long may our land be bright, with freedom's holy light. Protect us by your might, great God, our
king. And tonight we resoundingly affirm our nation's motto, In God, We Trust.

Accept our gratitude for our mayor, her colleagues who share with her on our City Council, and their
support staff. As citizens of Pismo Beach, we are most fortunate for such talented and skilled people to
lead our city, and give watchful care for our concerns. We invoke your wisdom to be graciously given
to each of them tonight as they seek solutions to make our city a better place to live, and to enjoy life.
This invocation we pray, in the name of our personal Savior and Lord . . . Amen.


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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
March 1, 2011
May I ask you again to bow your heart with me in prayer? Our Heavenly Father, each Wednesday
morning at 8 o'clock, when Congress is in session, a group of nearly twenty Senators meet to seek and
to pray for the guidance of God. These weekly sessions are a tradition of more than sixty years, and
during these prayer times they ask God to guide their personal lives and their lives as Senators. The fact
that so many of our great leaders have sought spiritual guidance from God the almighty is a testament
to the power of prayer. Throughout our history, citizens, and leaders as well, have been involved in
prayer to promote progress, to heal wounds, to enhance insight, and to win moral victories.
It was on January 27, 1983 that President Ronald Reagan declared, and I quote, Prayer is the
mainspring of the American spirit. Prayer is the fundamental tenet of our people, since before our
Republic was even founded. As citizens, we are somewhat aware of the chaotic times of unrest around
our world, and within our country. And so tonight, we join our hearts with President George
Washington and pray again the prayer that he prayed, and I quote, Almighty God, we make our
earnest prayer that you will keep the United States in your holy protection.
90

We pray that you would cause our President Obama, and our leaders in Washington, and our leaders in
every state, to take your wisdom and your guidance as they deal with our domestic and foreign issues
of urgency. We pray tonight for our City Council, as they seek to privately and to personally govern
our city. We our grateful for our mayor, Shelly Higginbotham, and her fellow council members, and
their talented staff whom you have given to support them. May each of us citizens seek to keep the
ways of the Lord, and to live righteously before you. And as we do, your abundant blessings will
continue upon the leaders of our city. Your abundant blessings will continue upon each of us as
citizens, and your abundant blessings will continue upon the tens of thousands of guests who visit our
beautiful city each year. This prayer of invocation we pray, in the name of our personal Savior and
Lord . . . Amen.
90
This is not accurate. This was written by one of Washingtons aides, David Cobb, in a June 8, 1783 letter to the
governors of the states, I now make it my earnest prayer, that God would have you, and the State over which you preside,
in his holy protection, that he would incline the hearts of the Citizens to cultivate a spirit of subordination and obedience to
Government, to entertain a brotherly affection and love for one another, for their fellow Citizens of the United States at
large, and particularly for their brethren who have served in the Field, and finally, that he would most graciously be pleased
to dispose us all, to do Justice, to love mercy, and to demean ourselves with that Charity, humility and pacific temper of
mind, which were the Characteristicks of the Divine Author of our blessed Religion, and without an humble imitation of
whose example in these things, we can never hope to be a happy Nation. The writings of George Washington from the
original manuscript sources 1732-1799, (ed. John C. Fitzpatrick, U.S. Govt Print. Off.) Vol. 26, page 496.
http://etext.virginia.edu/etcbin/ot2www-
washington?specfile=/texts/english/washington/fitzpatrick/search/gw.o2w&act=surround&offset=33279213&tag=Writings
+of+Washington,+Vol.+26:+CIRCULAR+TO+THE+STATES&query=earnest+prayer&id=gw260534
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 15, 2011

Would you please bow your heart with me in prayer? Our Heavenly Father, President Dwight D.
Eisenhower proclaimed in 1955 these words, and I quote, Without God, there can be no American
form of government, nor American way of life. Recognition of the Supreme Being is the first, and the
most basic, expressions of Americanism. Our founding fathers recognized this with Gods help, it will
continue to be. Every session of the House of Representatives and U.S. Senate begins with a prayer.
Each House has its own full time chaplain. The 83
rd
Congress set aside a room in the capitol, just off
the rotunda, for the private prayer and meditation of members of Congress. The focal point is a stained
glass window showing George Washington kneeling in prayer, and behind him etched the words of
Psalm 16, verse 1, Preserve me, oh gods. For in thee do I put my trust.
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The intimate relationships
our Presidents and elected leaders have enjoyed with the living God inspire us today. And so we boldly
affirm the words of our national motto, In God, We Trust.

As we pray today, we especially remember the nation of Japan. Last Friday was rocked by a 9.0
earthquake, and attending tsunami. Entire towns have been destroyed and the loss of human lives and
those missing number into the tens of thousands. Their grief, and their loss, can only be imagined by
us, and so we pray from our heart the comfort of our loving Lord, and his eternal strength will help to
regulate their emotions as they endeavor to clean up this disaster and look into the future. May the
injured sense the power of your presence.

We thank you again for your divine protection upon our country. May each of us demonstrate our
gratitude by leading righteous lives that honor and please You. We invoke your divine wisdom and
understanding upon our mayor, the members of our City Council, and their support staff. May our City
Hall, and these Council chambers, be hallowed and filled with your abiding presence, and may our city
be affected by your nearness in the lives of every citizen, and the guests who visit our beautiful city.
This invocation we pray, in the name of Him who loves us, and who cares for us, our personal Savior
and Lord . . . Amen.



91
The event portrayed in the window did not happen.
Psalm 16:1-1 Keep me safe, my God, for in you I take refuge. I say to the Lord, You are my Lord; apart from you I have
no good thing. I say of the holy people who are in the land, they are the noble ones in whom is all my delight. Those who
run after other gods will suffer more and more. I will not pour out libations of blood to such gods or take up their names on
my lips.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 5, 2011

Will you please bow your heart in prayer with me? Our Heavenly Father, national unrest has caused
protestors to fill the cities of Egypt and topple a government of long standing. Tunisia has been in a
bloody protest. Protest marches and killings are happening today in Syria. Unrest is being manifest in
Jordan and Saudi Arabia. Libya is engaged in a bloody civil war to drive out a ruthless dictator of some
42 years, and many protestors are dying in Yemen as we pray this prayer. And our country is involved
in two long wars in Iraq and Afghanistan, and Japan's recent 9.0 earthquake and the attending tsunami
has created a nuclear disaster that appears to defy human solutions.

But at this time we are reminded of an event in the life of Conrad Hilton, who founded the Hilton hotel
chain. During our fight with Communism in the Cold War, he published a prayer, a full-page prayer, in
major magazines, July 4, 1952, across the length and breadth of our country, and I pray that prayer
today, verbatim, 51 years later: Our Father in Heaven, we pray that you save us from ourselves. That
world that you have made for us to live in peace, we have made into an armed camp. We live in fear of
war to come. We are afraid. We have turned from you to go our selfish way. We have broken Your
Commandments, and denied Your Truth. We have left your altars to serve the false gods of money, and
pleasure, and power. Forgive us, and help us. And now darkness gathers around us, and we are
confused in all our counsels. Losing faith in you, we lose faith in ourselves. Inspire us with wisdom, all
of us, of every color, every race, and every creed, to use our wealth and our strength to help our brother
instead of destroying him. Help us to do Your Will as it is done in Heaven, and to be worthy of your
promise of peace on earth. Fill us with new faith, new strength, and new courage that we may win the
battle for peace. Be swift to save us, dear God, before the darkness falls.

And tonight, Our Father, in true humility we also pray: Lord, save us. May your invisible presence be
sensed by all who work at City Hall, and each of us in these Council chambers. Only you have the
solutions to the challenges and needs that are faced by our national leaders, and the members of our
City Council, and so we invoke your wisdom and your understanding to fill their hearts and their minds
with confidence to meet each challenge and each opportunity in which they and their staff will be
involved. May righteousness so be a part of our daily conduct as to allow your continued blessings
upon our City, upon our citizens, and the guests who visit our beautiful city. This invocation we pray,
in the name of our Gracious Redeemer and Lord . . . Amen.



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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 19, 2011

Will you please bow your heart in prayer with me? Our Heavenly Father, today is April 19
th
. This day
is rich in the history of our great country. On this day in 1865, funeral services were conducted for our
slain President, Abraham Lincoln. On this date in 1933, President Franklin D. Roosevelt announced the
U.S. is going off of the gold standard, and this same day in 1951, General Douglas MacArthur was
relieved of his command by President Harry Truman and then gave his farewell address to Congress in
which he coined the phrase old soldiers never die, they just fade away. But perhaps the best known
event was this day in 1775, the American Revolutionary War began in the villages of Lexington and
Concord near Boston. Someone fired a shot as 700 British redcoat soldiers engaged 75 minutemen and
in just a matter of seconds, eight dead and ten wounded minutemen lay on the Lexington Greens. But
as the redcoats returned to Boston, minutemen lay in ambush behind trees and rocks and woodpiles.
Snipers plagued these British soldiers and by nightfall 250 redcoats were killed or wounded, and the
colonists had lost 90 minutemen. Hundreds of militiamen shouldered their muskets and marched to
Boston, and the struggle for our American independence had begun. On this day, April 19, 1775,
Americans fired the shot that was heard around the world.

Two years later, September 17, 1777, the Continental Congress convened. Leaders present that day
included George Washington, John Rutledge, Patrick Henry and John Jay, the first Chief Justice of the
Supreme Court. These were joined with Puritan patriots of New England in fervent prayer, and I pray
today just a part of the prayer they prayed that day, and I quote: Almighty God, may order and
harmony and peace be effectually restored, and may justice and truth and righteousness prevail and
flourish among the people. John Adams wrote his wife Abigail, and said these words: Their emotions
as they turned, imploring heaven for divine interposition, was enough to melt a heart of stone.
92


92
A search of the text of letters between John and Abigail Adams during the Revolution reveals no such quote; indeed, it
does not appear in any original, discernable source. Several letters had similar sentiments regarding melting hearts, but not
due to congressional prayers.

John Adams, July 7, 1774 letter to Abigail Adams, I am engaged in a famous cause,the cause of King, of Scarborough,
versus a mob that broke into his house and rifled his papers and terrified him, his wife, children and servants in the night.
The terror and distress, the distraction and horror of his family cannot be described by words or painted upon canvas. It is
enough to move a statue, to melt a heart of stone, to read the story.

John Adams, September 18, 1774 letter to Abigail Adams, These votes were passed in full Congress with perfect
unanimity. The esteem, the affection, the admiration for the people of Boston and the Massachusetts which were expressed
yesterday, and the fixed determination that they should be supported, were enough to melt a heart of stone.

John Adams, June 11, 1775 letter to Abigail Adams Millions will be upon their knees at once before their great Creator,
imploring his forgiveness and blessing; his smiles on American councils and arms.

John Adams, July 7, 1775 letter to Abigail Adams, Your description of the distresses of the worthy inhabitants of Boston
and the other seaport towns is enough to melt a heart of stone.

John Adams, June 26, 1776 letter to Abigail Adams, Our misfortunes in Canada are enough to melt a heart of stone. The
small-pox is ten times more terrible than Britons, Canadians, and Indians, together.

John Adams, April 13, 1777 letter to Abigail Adams, The graves of the soldiers who have been buried in this ground from
the hospital and bettering house during the course of the last summer, fall, and winter, dead of the small-pox and camp
diseases, are enough to make the heart of stone to melt away.


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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
And so today, Our Father, we repent of our sins, and we also pray that justice and truth and
righteousness would prevail among our generations of Americans. May we seek to live justly and
righteously, and be zealous for those things that honor God. Thank you for every member of our City
Council and their support staff. Infuse in them your wisdom and your understanding. Give your
solution for every difficulty and every opportunity that they face. We would invoke your invisible
presence and Your Will to be the resource that you graciously grant to our leaders, whom we have
elected. May proper decisions be made tonight, that will honor you and benefit the citizens and the
guests of our beautiful city. This invocation we pray, in the name of our personal Savior and Lord . . .
Amen.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 3, 2011

Will you please bow your heart with me in prayer? We join tonight we countless fellow Americans, our
Heavenly Father, who have celebrated the demise of Osama bin Laden this past week in Pakistan.
Brave and skilled U.S. Navy Seals practiced untiringly for months and carried out this mission with
military precision. Our President has declared our world is a better place because he is gone. President
George Washington spoke so clearly to his day, and likewise to our day, when he declared, and I quote
No people can be bound to acknowledge and to endure the invisible hand which conducts the affairs
of men more than those of the United States. So we offer to you, our God, sincere gratitude and
sincere appreciation for your continued blessings and bountifulness and protection to our country and
citizens. Continue to endow our intelligence community with your favor and with your skills, as they
seek each moment to protect each of us as citizens at home and abroad. And tonight, we unite our
hearts as a grateful people and boldly affirm our nation's motto, In God, we trust.

Thursday, day after tomorrow, has been declared our National Day of Prayer by Congressional
leadership. Even now, tonight, we bow our hearts in true humility, and ask your forgiveness of our
personal sins, and our sins as a nation. Cause us to walk uprightly, and cause us to pursue
righteousness, for the Bible teaches us from the writings of King Solomon, recorded in Proverbs 14:34,
Righteousness exalts a nation, but sin is a reproach and an embarrassment to any people.
93
And so
tonight we invoke your invisible presence to hallow these City Council chambers. May your wisdom
and your understanding be freely granted to our mayor, her fellow council members, and their support
staff. We pray that this will be the resource that becomes the solution to each situation and each
opportunity that we face. God, bless the citizens and the guests of our beautiful City of Pismo Beach.
God, bless and protect America. This invocation we pray, in the wonderful name of our Savior and
Lord . . . Amen.





93
Proverbs 14:34 -
NIV Righteousness exalts a nation, but sin is a disgrace to any people.
KJV Righteousness exalteth a nation: but sin is a reproach to any people.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 17, 2011

Please bow your heart with me in prayer. Our Heavenly Father, this coming Saturday, the third
Saturday in May, we will observe Armed Forces Day. As a nation we have celebrated this patriotic
holiday since 1950. This is a day to salute soldiers and all branches of the military and to remember
that we would have no peace, no security, no freedom, not even United States, without them. On
Memorial Day we honor America's war dead, on Veteran's day we honor those who have served in
day's past, but on Armed Forces Day we honor those who are presently serving in our military around
the globe. And so tonight, we honor our service men and women, serving our country so honorably in
Afghanistan, Iraq, Libya, Pakistan and many other needy areas in position of peril. Cause each of them
to understand we hold them in honored affection, and in exceptional esteem. Our Father we thank you
for the extraordinary privilege to be citizens of this great nation. We are aware that the greatness of
America is largely the result of our founding fathers honoring God and honoring the precepts of the
Bible. And so tonight, we wholeheartedly join our national leaders of generations past and affirm our
nation's motto, In God, we trust.

Thank you for our mayor, for every member of the City Council, and for their capable support staff. In
the midst of complicated situations, and in the midst of unresolved problems, deliver these our friends
from any sense of futility. Cause them to feel the support of the prayers daily of many of the citizens of
our great city, and above all, we invoke the uplift of your everlasting arms.
94
This invocation we pray,
in the wonderful name of our Savior and Lord . . . Amen.



94
Deuteronomy 33:26-27 There is no one like the God of Jeshurun, who rides on the heavens to help you and on the
clouds in his majesty. The eternal God is your refuge, and underneath are the everlasting arms. He will drive out your
enemy before you, saying, Destroy him!
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
June 7, 2011
Will you please bow your heart in prayer with me? Our Heavenly Father, James Madison was the
principal author of the U.S. Constitution; he was the father of the Bill of Rights; he was the fourth
President of our great country. He said, We have staked the whole future of American civilization, not
upon the power of government, far from it. We have staked the future upon the capacity of each and all
of us to govern ourselves according to the Ten Commandments of God.
95
These our fundamental
expressions of Gods design for man. To abandon our nation's moorings would be tragic. Today we
join our hearts with the American founding fathers of the past whose vision and courage shaped the
future of our country and in true repentance we ask you, our God, to protect, and to preserve, our
beloved country, and cause our leaders to honor and to follow you. Grant to each of our leaders
nationally, and locally, clear guidance and moral courage as they make decisions that directly influence
our policies and our laws. It is recorded in Holy Scripture that King Solomon declared in 930 B.C.,
God is a shield to those who put their trust in him,
96
and again he said, he who trusts in the Lord,
shall prosper,
97
and again he wrote, Whoever trusts in the Lord, shall be safe and secure,
98
and his
father, King David, before him wrote, He that trusteth in the Lord, mercy shall surround him all
about.
99
Our foreathers read, and re-read, these portions of Holy Scripture, and they anchored their
faith and their future to them. And, as a result, President Abraham Lincoln in 1863 had the phrase In
God, we trust. engraved on each U.S. Coin, and later this phrase was authorized to be printed on all
U.S. paper currency, and in 1956, the United States Congress passed a resolution declaring our national
motto to be, In God, we trust. And so today, we boldly affirm our nation's motto, In God, we trust,
and it is in this spirit that we pray this invocation.
We are grateful that all of us may be a part of this public City Council meeting. We invoke your
blessings upon council member. These are our friends. We have freely elected them to serve us, and we
pray for them daily. Cause each of them to understand that they cannot properly discharge their
responsibilities or their assigned tasks apart from your divine enablement. Bless them, and their support
staff, with the strength and the security of your invisible presence, and grant to each of them your
divine direction in their thought processes. This will bring proper solutions to each problem, and to
each need, that they encounter, and will benefit each of us as citizens and guests alike in our beautiful
City of Pismo Beach. This invocation we pray, in the name of our personal Savior and Lord . . . Amen.
95
This quote is false, or at least not attributable to James Madison. David Barton is responsible for putting this quote into
Christian pop-culture.
96
Proverbs 30:5
97
Proverbs 28:25
98
Proverbs 29:25
99
Psalm 32:10
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 21, 2011
(Reverend Paul Toms)

Thank you, will you join together please with a moment of prayer? Eternal God, Our Father in Heaven,
we come out of a busy day with all kinds of activities twirl around us, and now we come to an
important part of that day and we seek your blessing and your guidance, and your hand of
understanding upon us. We thank you today, O God, for the community in which we live. Blessed of
you, surrounded by beauty, quietness, success, challenges, blessings, understandings, people that are
trying to do the right thing. We are thankful for every good and perfect give that comes from you. You
look after us; you provide for our needs; you bless us beyond measure. We think of people today that
live in small towns or huge cities . . . in many parts of the world they have nothing to eat, they're
destitute, and they're threatened by war and climactic changes. Lord we thank you for what you have
done for us here. We don't deserve it, but we rejoice in it. Now we seek your hand of blessing
100
upon
this council. We thank you for these people, we thank that which they represent, they represent a
community, a community of fireman, policemen, who protect us and help us, a community of teachers,
a community of parents, a community of children and youth, a community of people who are dedicated
to the ways in which we can improve our life here in this place. Thank you for your help. We seek your
guidance upon us. Make this a useful, and successful and helpful meeting today. Give us guidance from
your hand. Help us to remember that, Blessed is the nation whose God is the Lord.
101
We trust you,
we ask you to help us and guide today in this meeting, through Christ our Lord, we ask it. Amen.



100
See e.g., Isaiah 25:10, 66:14; Psalm 139:5.
101
Psalm 33:12
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

July 19, 2011

Will you bow your heart in prayer with me, please? Our Heavenly Father, we bow our hearts before
you in the dignity of this city council meeting. The Scriptures teach us that blessed is the nation whose
God is the Lord.
102
We recognize that we are a nation under God. Our forefathers have handed us the
torch of faith. You alone have given us our freedoms, our liberties, and our wonderful prosperity.
Faith in God is not only our heritage, faith in God is our foundation. It was President George
Washington who reminds us, Morality and faith are the pillars of our republic, but it is evident that
the pillars are being eroded in our secular and permissive society. Too long we have neglected Your
Word. Too long we have ignored Your Laws. We have tried to solve our problems without reference
to you, but Your Word is clear. The Bible is simple, for it says, Righteousness exalts a nation, but sin
is a reproach and an embarrassment to any people. We confess to you our sins and ask that we as a
nation and we as individuals experience a moral and a spiritual restoration.

Our leaders in Washington, D.C., as well as our leaders in our beautiful city of Pismo Beach face
burdens and responsibilities that at times are overwhelming. So we pray tonight that you would cause
your divine guidance to rest mightily upon each of our leaders. In the moment of decision, give to
them your uncompromising courage to do what is morally right with a cool head and a warm heart. We
pray especially tonight for your divine understanding to rest strongly upon our U.S. intelligence
community. We want to thank you for the terrorist plots upon our nation that have been uncovered.
These would have inflicted severe damage to our citizens. Tonight we boldly declare our nations
motto, in God we trust. No only is this truth engraved on our currency, but we pray that it may also
be enshrined in our hearts and placed upon our lips. Surround us with your presence and your power as
we find our security from your promise which says I will never leave you; I will never forsake you.

Tonight we would remember those so near and dear to our city. We pray for Kevin Rice, our City
Manager, whose lovely mother fell just today and broke her nose. Will you help her and help Kevin
with your mighty healing power? We will not forget to pray for Burt Brunwin, whom so many of us
know, having seen him for so many years in our community, and the husband of our former Mayor
Maryann Reiss. We pray for him today as he suffers from a heart disorder. Bring healing and health to
him. We pray for so many shut-ins in our community such as Art Anthony and Elaine Anthony who
have been such a part of our community and our council meetings but no longer are able to do so. We
believe you to help them. Tonight may our mayor and her colleagues and their support staff rest
confidently in your ability to give solutions to every problem they face tonight and in the future. And
may our united desires always be that Your Word becomes our law and Your Will becomes our chosen
path. This invocation we pray in the name of Him who Isaiah called the Prince of Peace
103
but whom
we know as our personal Savior and Lord, in His name we pray. Amen.





102
Psalm 33:12
103
Isaiah 9:6 This is from the Old Testament, the belief that Jesus is the fulfillment of this prophecy is an exclusively
Christian idea, For to us a child is born, to us a son is given, and the government will be on his shoulders. And he will be
called Wonderful Counselor, Mighty God, Everlasting Father, Prince of Peace.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 2, 2011

Will you please bow your heart with me in prayer? Our Heavenly Father, President John F. Kennedy
said in 1961 in his inaugural address, The same beliefs our forbearers fought are still at issue around
the globe, the belief that the rights of man come not from the generosity of the state but from the hand
of God. This generation of Americans are unwilling to permit the slow undoing of this human right to
which this nation has always been committed.
104
And then he said, We shall pay any price. We shall
bear any burden. We shall meet any hardship. We shall support any friend. And we shall oppose any
foe in order to assure the survival and the success of liberty. Let us go, therefore, to lead this land we
love asking Gods blessing and Gods help but knowing that Gods work on Earth must truly be our
own. And then President Ronald Reagan said, Freedom is never more than one generation away
from extinction. We did not pass it to our children in the bloodstream. It must be fought for, protected,
and handed to them to do the same. How grateful we are for your abundant blessings, Our Father, you
have bestowed upon our great country, the Unites States of America.

Just a few days ago the young man who planned to make two bombs in his apartment and then do great
damage to his fellow Americans was apprehended and today is incarcerated behind bars in jail. The
goodness of God to America and to its citizens is great and we are deeply appreciative. We join our
hearts in praying the prayer of the songwriter, Long may our land be bright with freedoms holy light.
Protect us by thy might, great God our king. May our military men and women and their families
experience your protection and your peace and your loving care. We pray today that our President and
our national leaders who represent us will seek you and your guidance and rest securely in your ability
to grant solutions to every problem that our nation faces today and in the future. Cause our united
desires to always be that Your Will becomes our chosen path.
105


Tonight we invoke your divine presence to fill city hall and these council chambers. Grant that your
wisdom will be granted to our mayor and to her colleagues and to their support staff for the matters at
hand tonight and in the future. May we as Americans bless God, and may God bless America. Protect
our great country. Protect our citizens of Pismo Beach, and protect our guests who visit our beautiful
city. This invocation we pray in the name of our Loving Savior and Lord. Amen.



104
This is a heavily edited version.
105
Chosen Path is probably form Psalm 25 Show me your ways, O LORD, teach me your paths; guide me in your truth
and teach me, for you are God my Savior He guides the humble in what is right and teaches them his way Who, then, is
the man that fears the LORD? He will instruct him in the way chosen for him.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 16, 2011

Will you please bow your heart in prayer with me? Our Heavenly Father, each Wednesday morning at
8:00 a.m. when Congress is in session, a group of nearly 20 senators meet to pray and to eek the
guidance of God. These weekly sessions are a tradition of more than 60 years. During these prayer
times they ask God to guide their senatorial lives as well as their personal lives. The fact that so many
of our great leaders have sought spiritual guidance from God the almighty is a testament to the power
of prayer. Throughout our history, leaders and citizens have been involved in prayer to promote
progress and to heal wounds, to enhance insight and to win moral victories. It was on January 27, 1983
that then President Ronald Reagan declared, Prayer is the mainspring of the American spirit, a
fundamental tenant of our people since before our republic was founded. As citizens we are
sometimes aware of the chaotic unrest and upheaval around our world and in our own country. And so
tonight we join our hearts with President George Washington and pray again the prayer that he prayed
when he said, Almighty God we make our earnest prayer that you will keep the United States of
America in your holy protection.
106
So we pray tonight that you would cause President Obama, our
leaders in Washington, and leaders in every state across our great nation to seek your wisdom and your
guidance as they deal with domestic and foreign issues of urgency.

Tonight we especially remember many of our citizens who dwell in our city who in previous years
were very active in the affairs of our city, but with the passing of years and physical infirmities, they
can no longer participate. These are our friends and include such wonderful citizens as Art and Elaine
Anthony, Robert and Jane Rice, Burt Brunwin and many others. May these sense tonight the power of
your presence in their home as well as renewed strength in their bodies. And especially tonight we
pray for our city council as they seek to properly govern our city. We are grateful for our Mayor,
Shelly Higginbotham, her fellow council members, and the talented staff who support them. May each
of us as citizens seek to keep the ways of the Lord and live righteously before you. As we do, your
abundant blessings will continue upon the leaders of our city as well as each citizen and the guests who
visit our beautiful city. This prayer of thanksgiving and invocation, we pray in the name of our
personal Savior and Lord. Amen.

106
This is not accurate. This was written by one of Washingtons aides, David Cobb, in a June 8, 1783 letter to the
governors of the states, I now make it my earnest prayer, that God would have you, and the State over which you preside,
in his holy protection, that he would incline the hearts of the Citizens to cultivate a spirit of subordination and obedience to
Government, to entertain a brotherly affection and love for one another, for their fellow Citizens of the United States at
large, and particularly for their brethren who have served in the Field, and finally, that he would most graciously be pleased
to dispose us all, to do Justice, to love mercy, and to demean ourselves with that Charity, humility and pacific temper of
mind, which were the Characteristicks of the Divine Author of our blessed Religion, and without an humble imitation of
whose example in these things, we can never hope to be a happy Nation. The writings of George Washington from the
original manuscript sources 1732-1799, (ed. John C. Fitzpatrick, U.S. Govt Print. Off.) Vol. 26, page 496.
85
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 6, 2011

Let us bow our hearts in prayer. Our Heavenly Father, Karl Marx once said, If we can rip away
history from any people, they will easily be conquered.
107
We have learned that a bouquet of
beautiful roses soon die because they are cut off from their roots. Ethics, morals, standards of
behavior, these are not to be determined by a majority of people but by God himself. It was President
Harry Truman who said, The fundamental basis of this nations laws were given to Moses on the
mountain. The fundamental basis of our bill of rights comes from the teaching of Exodus, Isaiah, St.
Matthew and St. Paul. Let none of us believe the misconception that freedom is a license to sin or to
go our own way or to do as we wish, but help us always to understand that freedom is a responsibility
and power to do what is right, for no license is secure when removed from the roots that have been
established by God. Our U.S. Constitution was written by moral people. It was written for moral
people, and it will work for no other people. Our forefathers conceived freedom in their heart and they
wrote on our documents and yet freedom is not free. Our freedoms cannot survive without the personal
responsibility and our courage and our eternal vigilance. So help each of our civic leaders and each of
us as citizens to stand firm. Let us never be intimidated by numbers, but cause us to be men and
women of conviction who value moral righteousness above public acclaim. Grant the light of your
irresistible presence to avail so that no unrighteousness can prevail. As loyal citizens, we boldly
proclaim our nations motto, in God we trust.

And we invoke your favor upon the city of Pismo Beach as we confess and forsake our sins. Release
your blessings upon each of our citizens, all who work at city hall and serve our community. Give your
eternal wisdom to our friends who have freely elected to serve on city council. These are our friends.
For these we pray daily by name. Help them as they endeavor to make Pismo Beach a better place to
live and to enjoy life. And especially this evening, give your divine guidance to our mayor, each
council member, and their support staff. As next Sunday, September 11
th
draws near, we think of the
terrorist attack on our nation and its devastation and killing of nearly 3000 of our fellow citizens. We
pray for all who yet grieve today because of the unnecessary passing of their loved ones. We also
honor the memory of the firefighters and the policemen who gave their lives willingly so that others
might be saved. Thank you for your protection upon our land since that fateful day. Long may our
land be bright with freedoms holy light. Protect us by thy might, great God our King. This invocation
we pray in the name of our personal Savior and Lord. Amen.

107
No source can be located for this quote, it appears fictional.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 20, 2011

Will you please bow your heart with me in prayer? Our Heavenly Father, two great U.S. Presidents of
past generations continue to inspire and motivate us today. They are George Washington and Abraham
Lincoln. These were men who honored God and led our nation in righteous ways. Although our nation
faced extremely troubled times, they led in integrity and in truth. They were men of character who
were concerned about doing right more than securing high approval ratings. They read often the Holy
Scriptures and found direction range of motion them. They were men of prayer and understood that
they were answerable to you. As such, they were courageous to walk in obedience to what you
required of them. The Bible teaches us blessed is the nation whose God is the Lord.
108
Give to our
leaders the wisdom to know what is right and the will to do it. Cause us to understand the words of
Lincoln when he said, I have been driven many times upon my knees by the overwhelming conviction
that I had nowhere else to go. My own wisdom seemed to insufficient for the day. And so tonight we
boldly affirm our nations motto, in God we trust. Let us never forget that God promises security and
stability to all who put their trust in him, and history teaches us that God chooses human instruments
through whom he can infuse his life and his wisdom with spiritual and civil authority.

We are grateful for our city council and their support staff. Infuse in them your wisdom and your
understanding. Many problems they face seem to defy a solution. But your wisdom causes confusion
to fade into harmony. When our hearts and our minds are tuned to God in child-like trust, it is then that
God the invisible enables us to complete any assignment that he entrusts to us and to do it with courage
and successfulness. Tonight we invoke your irresistible presence and will to become the resource that
you give to each of the leaders of our city. May proper decisions be made tonight that will honor you
and benefit the citizens and guests of our beautiful city. This invocation we pray in the wonderful
name of our personal Savior and Lord. Amen.



108
Psalm 33:12
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 4, 2011
(Dr. Paul Toms)

Eternal God, Our Father, how grateful we are for all your good gifts to us. You protect us and keep us
and help us live in a wonderful place. You guide us in your sovereignty and we rejoice and return our
thanks to you. We pray today that you will bless our nation. We pray that you will grant that our ideas
and our aspirations will be in accordance with your perfect will. Grant unto us in this community just
government and just laws and grand unto us a good education system. Grant unto us justice in our
relationship to each other. May we please have a spirit of service in helping each other day by day.
Have mercy on us. Bless our humanity and its weaknesses. Deliver us from evil
109
and encourage us
as we try to do Your Will. We have come to a very important part today of our community life, and we
pause for a moment and give you thanks that we are able to do this. There are places in the world
where this is not allowed. We are grateful for the freedom that is ours. Bless we pray and help us
today in this meeting. We are thankful for people who encourage us and protect us through police
department and fire people who serve us in our teaching situation and our doctors and our nurses and
all kinds of good neighbors. We are thankful for what you do for us. We seek now your blessing upon
this council meeting. Decisions have to be made. They will reflect upon our lives, our money, our
future, our children. We commend it all into your loving care and pray that these people may be given
divine inspiration and understanding and help today as they make their decisions. We commend this
meeting and these your friends into your loving care through Christ, our Lord, we ask it. Amen.

109
This is a quote from the Lords prayer, which comes from Matthew 6:9-13 KJV:

After this manner therefore pray ye: Our Father which art in heaven, Hallowed be thy name. Thy kingdom come.
Thy will be done in earth, as it is in heaven. Give us this day our daily bread. And forgive us our debts, as we
forgive our debtors. And lead us not into temptation, but deliver us from evil: For thine is the kingdom, and the
power, and the glory, for ever. Amen.

It is interesting that this Book and Chapter were quoted, but verse 5 may be more apt: And when thou prayest, thou shalt
not be as the hypocrites are: for they love to pray standing in the synagogues and in the corners of the streets, that they
may be seen of men
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

November 1, 2011

Will you please bow your heart with me in prayer? Our Heavenly Father, our third President, Thomas
Jefferson spoke to our nation in 1781 and he said these words, God who gave us life, gave us liberty.
Can be the liberties of a nation be thought secure when we have removed their only firm basis, a
conviction in the minds of the people that these liberties are a gift of God?
110
And, 112 years later,
our 24
th
President, Grover Cleveland, gave these words at his second inaugural address, Above all I
know there is a Supreme Being who rules the affairs of men and whose goodness and mercy have
always followed the American people and I know he will not turn from us if we will humbly and
reverently seek his powerful aid. It is in this spirit tonight that we pray this invocation. We are so
grateful that our United States Congress passed a resolution in 1954 stating we are one nation under
God, and two years later in 1956 they stated that our national motto shall be, in God we trust. And so
we boldly affirm tonight that in God we trust.

We invoke your blessings upon the city of Pismo Beach and all who live here and all the wonderful
guests who visit our beautiful city. Release your blessings upon all who work at city hall and those
who serve in our community, in the police vehicles, and in the fire trucks, and we see the pickup trucks
going all over town and many men working on projects, and we stop so often and just greet them and
let them know how much we appreciate their faithful service to us as citizens of this community.
Cause each one to sense the strength and the security of your invisible presence. Give your eternal
wisdom to our friends whom we have elected to serve on our city council. From day to day help them
as they endeavor to make Pismo Beach a better place to live and to enjoy life. Especially tonight, give
your divine wisdom in the thought processes of our Mayor, Shelly Higginbotham, and each of her four
council colleagues. May the decisions that are made honor you and be for the betterment of all of our
citizens and our guests. This invocation we pray in the name of our wonderful personal Savior and
Lord. Amen.

110
Jefferson actually wrote this in two separate places more than 10 years apart.
1) The god who gave us life gave us liberty is from A Summary View of the Rights of British America (1774).
But let them [members of the parliament of Great Britain] not think to exclude us from going to other markets, to
dispose of those commodities which they cannot use, nor to supply those wants which they cannot supply. Still less
let it be proposed that our properties within our own territories shall be taxed or regulated by any power on earth
but our own. The god who gave us life gave us liberty at the same time: the hand of force may destroy, but cannot
disjoin them.
2) can the liberties Gift of God is from Notes on the State of Virginia, Query XVIII (1785). This is a comment
on the countrys acceptance of slavery: For in a warm climate, no man will labour for himself who can make
another labour for him. This is so true, that of the proprietors of slaves a very small proportion indeed are ever seen
to labor. And can the liberties of a nation be thought secure when we have removed their only firm basis, a
conviction in the minds of the people that these liberties are the gift of God? That they are not to be violated but
with his wrath? Indeed I tremble for my country when I reflect that God is just: that his justice cannot sleep for
ever . . .
89
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

November 15, 2011

Will you please bow your heart with me in prayer? Our Heavenly Father, we are grateful for the
privilege of the public gathering in our Pismo Beach council meeting tonight. We have elected our
mayor and her colleagues to our city council, and now in obedience to Holy Scripture we support and
undergird them with our prayers and our supplications in order that we may live a quiet and peaceable
life in all godliness.
111
Our U.S. history has taught us that Justice John Jay, the first U.S. Supreme
Court Chief Justice authorized prayer to be prayed to open each U.S. Court session,
112
and it is I this
spirit we offer to you our prayer of invocation tonight.

We pray for our city council publicly, having prayed for them daily by name in our personal prayers.
May each member of our city council accept their responsibility to lead our city and each of us as
citizens with single-mindedness of purpose and humility of spirit, for only then can we confidently
anticipate the favor and the guidance of our eternal God. We pause tonight just to say thank you for the
spirit of unity and peace that we enjoy in our city hall and in our city. Guide us with your wisdom
tonight to make wise decisions that will honor God and better conditions for the citizens of our
beautiful city of Pismo Beach. With your almighty help we can and we will resolve every problem and
situation that confronts us. Thank you for hearing our prayer. This invocation we pray in the name of
our wonderful Savior and Lord. Amen.

111
1 Timothy 2:1-2.
112
According to John Adams, When the Congress first met, Mr. Cushing made a motion that it should be opened with
prayer. It was opposed by Mr. Jay of New York, and Mr. Rutledge, of South Carolina, because we were so divided in
religious sentiments John Adams, Sept. 16, 1774 letter to Abigail Adams. Both Jay and Cushing served on the first
Supreme Court.
90
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 6, 2011

Will you please bow your heart in prayer with me? Our Heavenly Father, the story of Christmas is the
greatest story ever heard and ever told by mortal man.
113
More than 2000 Christmas days have come
and gone, but his story remains sacred memory. The names of Caesars and pharohs and emperors and
kings of all ages have come and gone and they are just a thought on the pages of history. Their
powerful armies are dust on the land and their mighty navies rust on the ocean floor, but the message of
the baby that was born in Bethlehems manger continues to live on.
114


Today, the celebration of His birthday causes traffic jams in New York City and Tokyo and Rio de
Janeiro. Every event in history and every event in our calendar is dated by how many years since this
baby boy was born in Bethlehem. His birth divides all time into B.C. (Before Christ) and A.D. (Anno
Domini, the year of his dominion).
115
Google has 373 million references to Christmas. Little wonder
our U.S. Congress 141 years ago, in 1870, by federal resolution, declared Christmas a national holiday.
We would pray tonight, oh Heavenly Father, that the peace that He brings to mankind would become a
reality in the hearts and minds of all those in the Middle East, in Iraq and Afghanistan, and Iran and the
Korean Peninsula. In the truest sense, let Earth receive her King. The message of Christmas is
evident in the lives of our citizens throughout Pismo Beach. In many stores, favorite Christmas carols
sing out words like, Silent Night, Holy Night, Oh Come All Ye Faithful, joyful and triumphant, and
Joy to the World, the Lord is Come. The strains of music and these words fill the air as they fill our
hearts.

Christmas teaches us that God is able and willing to bring life into the most barren settings and bring
hope into the most unpromising situations and bring hope into all of lifes circumstances for each of us
today. Thank you for your many gifts to us and our city this Christmas season. Thank you for the rains
that have fallen recently in our area, causing the hills and countryside to begin to turn green. Thank
you for our Mayor, Shelly Higginbotham, and our Mayor Pro Tem, Chris Vardas, and all of their
colleagues for a united city council and their wonderful support staff. We would invoke your guidance
through their skills and their talents, as they dedicate them to make Pismo Beach a better place and a
better place to live in 2011 and onward. This invocation we pray in the name of our personal Savior
and Lord. Amen.

113
The Christmas story comes from only one source, the Christian bible. Specifically from Matthew, chapters 1 and 2, and
Luke chapters 1 and 2.
114
Luke 2:12.
115
This is not accurate. Buddhism, Islam, Judaism, Bahai and Hindu all have their own calendar system. Some Eastern
Christian sects use the Julian calendar instead of the Gregorian. Ethiopia, Iran, China, and Thailand, both use their own
calendars
91
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
December 20, 2011
Will you bow your hearts with me in prayer, please? Our Heavenly Father, it is Christmastime in our
city and surrounding communities. Stores and shops are filled with carols and the beautiful music of
Christmas. We thank you that you have prospered so many of us that we may purchase gifts for those
we love and who are so dear to us. Allow your favor to rest upon our business community who have
planned so earnestly and worked so diligently to sell their goods and services and send sales tax and
bed tax to our city treasury. For your favor we are grateful. Let us understand anew that the message
of Christmas simple and beautiful. God wants to enter into all of lifes circumstances. And God
chooses a beginning point for his wonder workings in human beings.
Everybody is important, but tonight we pray for those families among us whose lives have been so
gravely impacted by the economic slowdown. Will you graciously provide for them, as only you know
how to do. At this Christmastime we pray for all of our military personnel as they serve the noble
cause of freedom and liberty around the world. May each one who is deployed be safe and secure and
may their loved ones have Gods comfort and presence as families are separated one from another, and
we would pause to say thank you, and our president announced this week that the nine year war in Iraq
had formally come to an end. For this we thank you. When our next city council meets, the Christmas
lights will be out. Christmas trees will have faded. Christmas ribbons will be forgotten and Christmas
lights will be packed away, but the babe that was born in Bethlehems manger will yet remain.
116
He
will comfort when we are sorrowful. He will provide meaning when lifes seasons seem so useless and
so empty. He will bring light when the way seems dark and he will provide joy when circumstances
are grim, and long after the carols have been hushed and long after the gift certificates have been
cashed, the baby that was born so long ago in Bethlehems manger will continue to bring happiness and
satisfaction, for His Name is above all other names. His Reign is above all other rulers. His Lordship
is above all other authorities. His Words are above all other voices, and his truth is above all other
opinions. His love is above all other affections.
Tonight we would invoke your divine presence. Fill city hall daily with your presence and fill these
council chambers tonight with your presence. Give your wisdom to our mayor, her colleagues, and
their support staff for the matters that are at hand tonight and in the future. We would thank you, Lord,
for the graciousness of George Edes to serve so many years as the chief financial officer for our city.
Tonight is the last night that George will be with us in a city council meeting, for he will be retiring at
the end of this month. Bless him with health and strength and we would ask, Lord, that you would give
us someone in his place who will be as skilled and steadfast as George has been these past years. God,
bless America. Protect our great country. Protect the citizens of Pismo Beach and the guests who visit
our beautiful city. This invocation we pray this holy Christmas season in the name of Him who was
born in Bethlehems manger and who has become our personal Savior and Lord. Amen.
116
Luke 2:12.
92
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

January 17, 2012
(Dr. Paul Toms)

Thank you, madam mayor. It is a pleasure to be with you once again. I am glad to fill in for my friend
Paul Jones. Its hard to fill in for him, as you know, but well do what we can. So join with me if you
will, please, in a moment of prayer. Eternal God, our Heavenly Father, we pause to remember people
who have been in our midst. We are aware of the quickly passing events of life. We are aware of the
blessings that we have. We are aware of how it is necessary to make the most of what we have day by
day. We think you for bringing us together here in this important meeting.

We seek your hand of blessing
117
upon us. We pray for our nation today. We are grateful for this
country. We are grateful for its past and its history. We are grateful for people who lead us. We thank
you for the opportunities that stretch before us, but we need your help. People are telling us every day
these days how they can help us and direct us. We need guidance and direction. We need help from
your loving hand.
118
Bless us as a nation. Thank you for our community. Thank you for the people
that surround us. Thank you for the people that help us. Thank you for the people that encourage us.
We are grateful specifically for this community that is represented here in the room today.

We seek your blessing upon this council and other people who are here on official business. We are
grateful for people who give of themselves in dedication, devotion. We are thankful for people in the
police department. We are thankful for people in the fire department, for our school teachers, and
others who influence us and help us. We are thankful for families. We rejoice in the sounds of little
childrens voices here. We seek your blessing upon our families. Watch over them. Help them. Bless
our youth and our children. Bring them up, help them; they face all kinds of challenges. We pray that
we as older people may be good models and good influences in their lives. Bless us now as we go
through these activities today. Give wisdom and understanding. Give a sense of peace and joy to the
members of the council that they may find satisfaction in what they do and that their efforts may be
well received and blessed of Your Hand.
119
Guide us now and keep us and encourage us by your
wisdom and by your love. We thank you for all that you do, and we pray these things through Christ
our Lord. Amen.

117
See e.g., Isaiah 25:10, 66:14; Psalm 139:5.
118
See next note
119
1 Chronicles 4:10 Jabez cried out to the God of Israel, Oh, that you would bless me and enlarge my territory! Let
Your Hand be with me, and keep me from harm so that I will be free from pain. And God granted his request. The
Christian bible continually references its god as Your Hand. See, e.g., Psalm 21:7-8 For the king trusts in the Lord;
through the unfailing love of the Most High he will not be shaken. Your hand will lay hold on all your enemies; your right
hand will seize your foes.; Psalm 74:10-11 How long will the enemy mock you, O God? Will the foe revile your name
forever? Why do you hold back your hand, your right hand? Take it from the folds of your garment and destroy them!;
Micah 5:9 Your hand will be lifted up in triumph over your enemies, and all your foes will be destroyed.; Psalm 139:5,
10; Deuteronomy 3:24; Isaiah 26:11; 1 Kings 8:24; 2 Chronicles 6:15; Acts 4:29-30; Psalm 17:14; Job 1:11; Job 10:7.

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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

February 7, 2012

Will you please bow your heart in prayer with me? Our Heavenly Father, George Washington, the first
president of our great country said, It is the duty of nations to acknowledge the providence of almighty
God, to obey his will, to be grateful for his benefits, and to humbly implore his protection and favor.
Later, James Madison, the fourth president of our great country said, Before any man can be a
member of civil society, he must be considered as a subject of the governor of the universe. The
founding fathers of our country believed wholeheartedly the words of the Holy Scriptures, which are
recorded in Psalm 33. The Word of the Lord is right. The Earth is full of the goodness of the Lord.
Blessed is the nation whose God is the Lord.
120
Because of the legacy left to succeeding generations,
we understand more fully why the U.S. Congress voted the motto of our nation to be, in God we
trust. And as American citizens of this generation, we proclaim forthrightly in God we trust.

Cause us, Lord, to be ever mindful that no one is secure in their own accomplishments. Our positions,
our achievements never make us invincible. God promises to us security and stability to those who
choose to put their trust and their confidence in him. May we always seek to live justly and to live
righteously and to be zealous for the things that honor God. Thank you for each member of our city
council and their capable support staff. Infuse in them your wisdom and your understanding. Give
your solution to every difficulty and to every opportunity that they face. We tonight invoke your
irresistible presence and will to become the source that you graciously grant to each of the elected
leaders of our city. May proper decisions be made tonight that will honor you and benefit the citizens
and the guests of our beautiful city. This invocation we pray in the name of our personal Savior and
Lord. Amen.





120
Psalm 33:4-12


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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
February 21, 2012
Will you bow your heart with me in prayer? Our Heavenly Father, our beloved nation, the United
States of America, was founded by men whose think and whose founding documents were influenced
by the Bible, the Holy Scriptures of God. Our Declaration of Independence identifies the source of all
authority and all rights as their creator. Individual human rights were got-given, not man made. There
was no king or established religion that could stand in the way of human liberty and human dignity.
These are unique Judeo-Christian ideals. The 55 delegates to the Constitutional Convention
represented the religious sentiments of those who shaped the political foundations of our great nation.
They were deeply influenced by a biblical view of mankind and government. Their personal writings
declare their strong religious beliefs and their faith. Their leadership in establishing and guiding
organizations such as the American Bible Society gives overwhelming evidence of their commitment
to righteousness.
121
Little wonder, under the leadership of Dwight D. Eisenhower, the Congress passed
a resolution declaring our nations motto to be, in God we trust. And tonight as American citizens
we boldly affirm in God we trust.
We acknowledge your gracious hand and your guiding hand in our nation and in our beautiful city of
Pismo Beach. We invite Gods blessing to rest upon our mayor and the members of our city council.
We have elected these, our fellow citizens, and we pray for them daily. Our city council and their
skilled support staff seek earnestly to make Pismo Beach a better place to live and to enjoy life with our
families and our friends, and tonight allow the power of your eternal presence to cause their thought
processes to respond to your divine guidance. May the decisions that are made tonight honor you and
be for the betterment of all our citizens and guests who visit our city. This invocation we pray in the
name of our personal Savior and Lord. Amen.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 6, 2012

Will you please bow your heart in prayer with me? Our Heavenly Father, before Moses, the leader of
Israel, had the Israelis enter the Promised Land he reminded them of the choice that God had put before
them. In Deuteronomy chapter 30, verse 15 the Holy Scriptures record, See? Ive set before you
today life and good, death and evil, and that I command you today to love the Lord your God, to walk
in his ways, to keep his commandments, his statues, and his judgments that you may live and multiply
and the Lord your God will bless you in the land which you go to possess.
122
God is asking America
to make the same choice today in order for us to rebuild Americas crumbling moral foundation. God
has made it clear that he will continue to bless our land if we choose to love him and walk in his ways.
As a nation and as individuals, we can stand before almighty God and say to him, we love you Lord,
and as a people we will walk in your ways and keep your commandments.

Daniel Webster, the great American statesman, urged us as a nation under God, to steadfastly guard
our foundation of righteousness. And in 1852, he declared, If we reject religious instruction and
authority, if we violate the rules of eternal justice, if we trifle with the injunction of morality, if we
recklessly destroy the political constitution which holds us together, no man can tell how suddenly a
catastrophe may overwhelm us that shall bury all our glory in profound obscurity. And God has made
it clear he will continue to bless our land as long as we choose to love him and walk in his ways. And
it is in this spirit that we boldly our nations motto, in God we trust. The words of King Solomon
motivate us tonight, for he said, The Lord loves those who pursue righteousness, for he pursues
righteousness finds life and prosperity and honor.
123


And in heartfelt humility, we invoke your continued favor upon our nation and upon our city. Release
your divine wisdom to be graciously bestowed upon each member of our city council and each
dedicated staff members. Fill these council chambers as well as each home in our beloved city with the
peace and the power of your divine nearness. May each individual citizen and each guest of our city
feel the impact of your irresistible presence. Tonight, may God be honored and each of us benefit in all
that is said and done. This invocation we pray in the name of our wonderful Savior and Lord. Amen.




122
The following verses continue, But if your heart turns away and you are not obedient, and if you are drawn away to bow
down to other gods and worship them, I declare to you this day that you will certainly be destroyed. You will not live long
in the land you are crossing the Jordan to enter and possess.
123
This is a n amalgamation of Proverbs 15:9 and Proverbs 21:21
Proverbs 15:9 The Lord detests the way of the wicked but he loves those who pursue righteousness.
Proverbs 21:21 He who pursues righteousness and love finds life, prosperity and honor.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

March 20, 2012

Will you please bow your heart with me in prayer? Our Heavenly Father, we bow our heads and our
hearts in humble gratitude for the needed rain that you sent to our area this past weekend. Thank you
that it did not come as hard pelting rain but rather it came somewhat gentle and the ground has received
and contained it. The native hillsides are green everywhere. This speaks to our hearts of your loving
care for us and our needs and we are so grateful.

Tonight we are reminded of the prayer prayed by Admiral Barry Black who is a retired U.S. Navy
Chief of Chaplains and the current Chaplain of the United States Senate. He prayed this prayer more
recently, Lord, thank you for this great land and for our freedom. May the liberty you bring keep our
feet in right paths. Eternal Lord God today and always give us wisdom to perceive you. Give us
intelligence to understand your ways. Give us diligence to seek you. Give us patience to wait on you.
Give us eyes to see you. Give us a heart to meditate on you. And give us a life to proclaim you. Give
our leaders in Washington, D.C. and throughout our land the desire to seek your wisdom and the
courage to follow your guidance so that your ways will become our chosen paths. We earnestly pray
that you will help us to become once again a nation whose God is the Lord.
124
From time to time
many unfavorable circumstances exist in the lives of citizens in our community. May they receive
strength by the promise of Holy Scripture as recorded in Psalm 35:15, which says, The eyes of the
Lord are upon the righteous and his ears are open to their cry.
125


We are most grateful for each member of our city council and their distinguished staff. Infuse in their
hearts and minds your design wisdom and life with spiritual and civil authority. We join with each of
them in invoking your divine presence to be the resource that becomes the solution to every situation
we face. God bless the citizens and the guests of our beautiful city, and God bless and protect America,
our beloved country. This invocation we pray in the name of our Blessed Savior and Lord. Amen.



124
Psalm 33:12
125
Psalm 34:15 actually, Psalm 35:15 reads But when I stumbled, they gathered in glee; attackers gathered against me
when I was unaware. They slandered me without ceasing.
97
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 3, 2012

Will you bow your heart with me in prayer? Our Heavenly Father, President John F. Kennedy said in
his 1961 inaugural address, The same beliefs our fore-bearers fought are still at issue around the
globe, the belief that the rights of man come not from the generosity of the state but from the hand of
God. This generation of Americans are unwilling to permit the slow undoing of these human rights to
which this nation has always been committed. We shall pay any price. We shall bear any burden. We
shall meet any hardship. We shall support any friend. We shall oppose any foe that would assure the
success and the survival of our liberties. Let us go forth to lead the land we love asking Gods blessing
and help but knowing that Gods work on Earth must truly be our own. Then President Ronald
Reagan joined in just a little later declaring, Freedom is never more than a generation away from
extinction. We did not pass it to our children in the bloodstream. It must be fought for and protected
and handed to them to do the same. How grateful we are for your abundant blessings which you have
bestowed upon our great country, the United States of America. We ask that you will give our leaders
the desire to seek your wisdom and the courage to follow your guidance. Help us to be a nation whose
God is the Lord.
126
The goodness of God to American and its citizens is great, and we deeply
appreciate them.

And so we pray, long may our land be bright with freedoms holy light. Protect us by thy might, great
God our king. May our military men and women and their families experience your protection and
your peace and your loving care. May our President and our national leaders who represent us seek
you in your guidance and rest securely in your ability to grant solutions to every problem that our
nation faces today and in the future. Cause our united desire to always be that Your Will becomes our
chosen path. Tonight we invoke your divine presence to fill city hall and to fill these county chambers.
Grant your wisdom to our mayor and to her colleagues and to their support staff for the matters at hand
tonight as well as in the future. May we as Americans bless God. And may God bless America.
Protect our great country. Protect the citizens of Pismo Beach and protect our guests who visit our
beautiful city. This invocation we pray in the name of our personal Savior and Lord. Amen.


126
Psalm 33:12
98
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

April 17, 2012

Our Heavenly Father, President Abraham Lincoln said on March 30, 1863 it is the duty of nations as
well as individuals to own their dependence upon the overruling power of God. And the Holy
Scriptures announced this sublime truth proven by all history that those nations only are blessed
whose God is the Lord.
127
We as a nation have been recipients of the choice bounties of heaven.
We have preserved and persevered in peace and prosperity, but we have forgotten the gracious hand
that preserved us and multiplied us and enriched us and strengthened us. Societies decay when their
foundation principles erode. Great nations die from within. It is the moral influence and the failure of
the country to remember what made it great. We are convinced tonight that we, too, must humble
ourselves as individuals and as a nation. It is vital that we ask your forgiveness of our sins and our
failures, and we declare tonight that our great and beloved nation, the United States of America, will
continue to be blessed only as we allow the Lord to be our God. So, boldly tonight we affirm our
nations motto, in God we trust.

In obedience to Holy Scripture, we invoke your divine presence and wisdom upon our mayor and her
colleagues and their support staff. We understand that good government is a principle that originated at
the heart of God, and so may your wisdom and courage be given to each of them to make good
decisions. Grant that each decision will honor God and be for the betterment of all the citizens of
Pismo Beach and the wonderful guests that visit our beautiful city. Thank you for Lori who has come
once again, having worked here so many years, and now these last months has come to serve as our
interim city clerk. We love her and appreciate her. Bless her as again she enters retirement. We thank
you for hearing and responding to our prayer. This invocation we pray in the name of our personal
Savior and Lord. Amen.

127
Psalm 33:12
99
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 1, 2012

Will you please bow your heart with me in prayer, please? Our Heavenly Father, President Calvin
Coolidge, our 30
th
President of the United States said, If American democracy is to remain the greatest
hope of humanity, it must continue abundantly in the faith of the Bible. The leaders of our nation
strongly believe this and in 1952 by a joint resolution of Congress, the first Thursday of May each year
was designated as a National Day of Prayer. This day is designated as a day of focused prayer for our
nation. The day after tomorrow is May 3
rd
, the first Thursday of May. Each of us are privileged to be a
part in our own time and our own way in the annual observance of this National Day of Prayer. God is
true to his character. As we seek his faith in prayer and respond to the Holy Scriptures, it will change
the way we think and the way we behave. Sin and spiritual decline removes the favor of God, but if we
repent, God will forgive and pardon our sins and replace them with his righteousness in our lives.
Each day we rest upon the unfailing promise recorded in Isaiah, chapter 41, verse 10: Fear not, for I
am with you. Be not dismayed, for I am your God. I will strengthen you. I will help you. I will
uphold you with my righteous right hand. Knowing this, we confidently affirm our nations motto,
in God we trust.

And in heartfelt humility, we ask tonight for your protection and your favor upon our nation and its
citizens. We especially pray for those who are ill and shut-in. We also remember those who are being
adversely affected by the economic slowdown in our nation. We ask your divine presence and power
to comfort and to strengthen them and their families. We invoke your divine wisdom to be bestowed
on each member of our city council. We ask you to provide solutions to each problem and each need
that they face tonight. We declare our responsibility to pray for your leadership in the lives and the
decisions of our council and their support. Fill city hall and these council chambers with the peace and
the power of your divine presence. May each home and each citizen and each guest of our city sense
the impact of your presence in our city. This invocation we pray in the name of our personal Savior
and Lord. Amen.
100
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

May 15, 2012

Will you bow your heart with me in prayer, please? Our Heavenly Father, Karl Marx once said, If we
can rip history away from people, they will easily be conquered.
128
We know that a bouquet of roses
die when they are cut off from their roots, and we clearly understand that no liberty and no freedom is
secure when our roots are removed, those roots that have been determined by God, for ethics and
morals and standards of behavior, these are determined by God. They are not determined by a majority
of people. Dr. Robert George of Princeton University said, Societies decay when their foundational
principles erode. Great nations die from within. It is the moral influence, the failure of the country to
remember what made it great. History shows that when countries allow their societies to become
amoral, they allow different kinds of immoral activities and lifestyles to flourish, and there is a price
thats paid, not just by the individuals engaged in that lifestyle, but by society as a whole.
129


So enable each of us, Our Father, to stand firm in our convictions, understanding that it is an honor and
a privilege to stand for right. May the deep abiding sense of Gods holiness and Gods righteousness
always determine our sets of right and wrong. Tonight, we strongly affirm our nations motto, in God
we trust. Help us to maintain this firm conviction in our hearts and in our lifestyles. Only then we
will not be helpless or defenseless as we face the future with confidence.

We thank you for the privilege of meeting tonight in this city council meeting, conducted openly in
public for the benefit of our citizens. We ask that your invisible presence will fill our city hall daily as
well as our council chambers tonight. We pray that each of our council members will understand that
we love them and that we have freely elected them to serve and to govern us. We pray for them
publicly tonight, because we have prayed for them by name daily in our private prayers. Grant that our
mayor, our city council members, and their support staff will be generously given your divine wisdom
and guidance for the matters that are at hand tonight and in the future. God, bless and protect America,
our leaders, and our military forces that are deployed around the world. God, bless and protect our
citizens of Pismo Beach and the guests who visit our beautiful city. We invoke your divine leadership
tonight upon all who lead our city. This invocation we pray in the name of our personal Savior and
Lord. Amen.



128
No source can be located for this quote, it appears fictional.
129
Dubbed by the New York Times this countrys most influential conservative Christian thinker. David D. Kirkpatrick,
The Conservative-Christian Big Thinker, The New York Times, Dec. 16, 2009, available at
http://www.nytimes.com/2009/12/20/magazine/20george-t.html?pagewanted=all&_r=0.
101
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 5, 2012
(Reverend Paul Toms)

Join with me please in a moment of prayer. Eternal God, Our Father in heaven, we give you thanks
today for your good gifts to us. It is proper and fitting that in the midst of intricate and important
discussions we should pause and invoke your presence. The Scripture says that if any man lack
wisdom, let him ask of God who gives to all men liberally.
130
We need your wisdom. We need your
Will. We need to understand what is right and proper and fitting, and that is not always easy to
discover, so we turn to you for help. Bless this council and all who in leadership here today. We
commend them into your care. We thank you for people who give of themselves and their
backgrounds, their training, and their interests. We seek your blessing upon us. Thank you for all that
you do. We are grateful for our community. We are grateful for the people who help us in service, for
our police people, our fire department people, and our school people who take care of our children. We
thank you for all who give of themselves in service and activity. Bless this community and bless this
meeting today and guide us and direct us, we pray, through Christ our Lord. Amen.




130
James 1:5

102
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

June 19, 2012

Will you bow your heart in prayer with me, please? Our Eternal God, Noah Webster has been called
the father of American scholarship and education. He gave us the first American dictionary of the
English language. To do so, he learned 26 languages. He said, Education enlightens the
understanding. It corrects the temper and informs the manner and habits of youth, and it fits them for
usefulness in their future stations in life. To give them a good education in manners and arts and
science is important, but to give them a religious education is indispensable. An attempt to conduct the
affairs of a free government with wisdom and impartiality and to preserve the just rights of all citizens
without the guidance of divine precepts will certainly end in disappointment, for God is the supreme
moral governor of the world that he has made and if men will not submit to be controlled by his laws,
they will be punished by the evils resulting from their own disobedience, and any system of education
which limits instructions to arts and sciences and rejects the age of religion informing the characters of
citizens is essentially defective.

We learn so much from the principles and the statements left to us, Our Father, by our early founding
fathers, and tonight in the invocation we sense anew the heart of this American patriot and we boldly
affirm our nations motto, in God we trust. As our fathers did, so we look to you, the protector and
provider and the promise of hope for our nation. Cause us to return to that firm foundation upon which
our great nation was built. Let your favor and your blessings be upon each member of our military who
serves with dedication and faithfulness throughout our troubled world. We invoke your divine
presence to fill these council chambers. Give your wisdom to our mayor, her colleagues, and their
support staff. God bless America. God, protect our great country, and God, protect each citizen of
Pismo Beach, and protect each guest who visits our beautiful city. This invocation we pray in the name
of our Lord and our Dearest Friend. Amen.
103
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

July 17, 2012

Will you bow your heart in prayer with me, please? Our Eternal God, Abraham Lincoln is thought by
many to be the greatest of all of our 44 presidents. He served during a most difficult period of
American history, the Civil War. The statue of Lincoln in the Lincoln Memorial in Washington, D.C.
portrays his most admired qualities. One of Lincolns hands is clutched tightly to indicate
determination and strength. The other hand is open and released, demonstrating the Presidents
compassion. Lincolns goal was preserving the Union as the last best hope on Earth. His reflections
of Gods role in American history are clearly stated. The Gettysburg Address consists of 267 words
and concludes with this phrase, This nation, under God, shall have a new birth of freedom. His
second inaugural address is composed of only 703 words, and in it he mentions God 14 times and
quotes the Bible two times.
131
Lincoln relied on the power of divine providence, stating, He who
made the world still governs it.
132
With such firm resolutions, we tonight affirm boldly affirm our
nations motto, in God we trust.

And it is in this spirit that we pray this invocation. We invoke your presence and protection upon all of
our military men and women, especially those in harms way. Bring them home speedily to their home
and loved ones. We pray your comfort on the family and friends of those who have paid the ultimate
sacrifice for our freedoms and our liberty. We invoke you invisible presence in the council meeting
tonight. You alone know our future, and only you can provide the strength and the wisdom to our
mayor and her colleagues and their support staff to meet the challenges as well as the opportunities that
they face. May your blessings rest upon our city. May your blessings rest upon every citizen, and may
your blessings rest upon each guest who visits our beautiful city. God, bless and protect America and
our City of Pismo Beach. This invocation we pray with a heart of gratitude to God. Amen.

131
Lincoln does not get to god until the second half of the speech and hes not so much relying on divine providence as
Jones suggests, hes pointing out what a terrible revenge divine providence is exacting: Neither party expected for the
war the magnitude or the duration which it has already attained. Neither anticipated that the cause of the conflict might
cease with or even before the conflict itself should cease. Each looked for an easier triumph, and a result less fundamental
and astounding. Both read the same Bible and pray to the same God, and each invokes His aid against the other. It may
seem strange that any men should dare to ask a just God's assistance in wringing their bread from the sweat of other men's
faces, but let us judge not, that we be not judged. The prayers of both could not be answered. That of neither has been
answered fully. The Almighty has His own purposes. "Woe unto the world because of offenses; for it must needs be that
offenses come, but woe to that man by whom the offense cometh." If we shall suppose that American slavery is one of those
offenses which, in the providence of God, must needs come, but which, having continued through His appointed time, He
now wills to remove, and that He gives to both North and South this terrible war as the woe due to those by whom the
offense came, shall we discern therein any departure from those divine attributes which the believers in a living God always
ascribe to Him? Fondly do we hope, fervently do we pray, that this mighty scourge of war may speedily pass away. Yet, if
God wills that it continue until all the wealth piled by the bondsman's two hundred and fifty years of unrequited toil shall be
sunk, and until every drop of blood drawn with the lash shall be paid by another drawn with the sword, as was said three
thousand years ago, so still it must be said the judgments of the Lord are true and righteous altogether. With malice
toward none, with charity for all, with firmness in the right as God gives us to see the right, let us strive on to finish the
work we are in, to bind up the nation's wounds, to care for him who shall have borne the battle and for his widow and his
orphan, to do all which may achieve and cherish a just and lasting peace among ourselves and with all nations.

132
This is from an Oct. 25, 1862 letter to Eliza P. Gurney, written some three years before the second inaugural, I have
sought his aidbut if after endeavoring to do my best in the light which he affords me, I find my efforts fail, I must
believe that for some purpose unknown to me, He wills it otherwise If I had had my way, this war would never have been
commenced; If I had been allowed my way this war would have been ended before this, but we find it still continues; and
we must believe that He permits it for some wise purpose of his own, mysterious and unknown to us; and though with our
limited understandings we may not be able to comprehend it, yet we cannot but believe, that he who made the world still
governs it.
104
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 7, 2012

Our Eternal God, the Pledge of Allegiance to the flag of the United States was created in 1892. It was
used in American public schools to celebrate the 400
th
anniversary of Christopher Columbus
discovering the new world. It has become a national oath to our country. It has become a motto of
unity. It has become a defense of the American way of life. It was used unofficially but recited daily
by school children for 50 years. In 1945 the pledge to the flag received its official title, the Pledge of
Allegiance, and in 1954, President Dwight D. Eisenhower approved the words, under god in the
pledge to differentiate the United States from the officially atheist Soviet Union. He declared, In this
way we are reaffirming the transcendence of religious faith in Americas heritage and in Americas
future, and in this way we shall continually strengthen those spiritual weapons which forever will be
our countrys most powerful resource in peace and in war. And so we as citizens of our city join our
city council members and our leaders in say aloud in unison the Pledge of Allegiance to the flag of our
great country in each official city council meeting. And today we also boldly affirm the motto of our
nation, in God we trust.

May our military men and women and their families experience your protection and your peace
wherever they serve around the world. May our president and our national leaders who represent us in
our republic seek you and your guidance. May they rest securely in your ability to grant your solutions
to each problem that our nation faces today and in the future. We pray that Your Will becomes our
chosen path. We invoke your divine presence to fill city hall and these council chambers. Grant your
wisdom to our leaders, to our mayor pro tem, to his colleagues, and to their dedicated support staff for
the matters at hand tonight as well as matters in the future. Long may our land be bright with
freedoms holy light. Protect us by thy might, great God Our King.
133
This invocation we pray in the
name of our Blessed Redeemer and our Dearest Friend. Amen.

133
See, Isaiah 33:22 For the LORD is our judge, the LORD is our lawgiver, the LORD is our king; it is he who will save
us.; Psalm 5:2 Listen to my cry for help, my King and my God, for to you I pray.; Psalm 44:4 You are my King and my
God, who decrees victories for Jacob.; Psalm 47:7-8 For God is the King of all the earth; Sing praises with a skillful
psalm. God reigns over the nations, God sits on His holy throne.; Psalm 74:12 But you, O God, are my king from of old;
you bring salvation upon the earth.; Psalm 95:3 For the LORD is the great God, the great King above all gods.; Psalm
145:1 I will exalt you, my God the King; I will praise your name for ever and ever.
105
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

August 21, 2012

Will you please bow your heart with me in prayer? Our Heavenly Father, John Adams was one of the
greatest founding fathers of our nation. He served as vice president under George Washington and then
was elected the second president of our great country. In October 1798 he wrote a letter to the militia
of Massachusetts. In it he stated, We have no government armed with power and capable of
contending with human passions unbridled by morality and religion. Ambition and revenge or
gallantry would break the strongest cords of our constitution as a whale goes through a net. Our
constitution was made only for moral and religious people. It is wholly inadequate to the government
of any other. And when Dwight D. Eisenhower took the presidential oath of office, he publicly placed
his hand on the Bible, opened to Psalm 33:12, which states, Blessed is the nation whose God is the
Lord. And it was during his presidential administration that the Congress of the United States passed
resolutions to 1) place under God in our pledge of allegiance to our flag, and 2) they voted our nations
motto to be, in God we trust. As American citizens in the 21
st
century, we wholeheartedly affirm our
nations motto, in God we trust.

We bend our hearts and faith in prayer in behalf of our City Manager Kevin Rice. His son was
severely injured in an automobile accident a week and a half ago. Already you have responded to the
united prayers of the citizens of our city and many others as well. We pray tonight to you as the one
who gave him life that you will restore him once again to good health and your blessings. Accept our
grateful thanks for his continued improvement. Tonight, we invoke the divine presence of God to fill
these council chambers. Give your wisdom generously to our mayor and to her colleagues and to their
dedicated support staff. God, bless America. God, protect our beloved country and protect each citizen
of Pismo Beach and each guest to visits our beautiful city. This invocation we pray in the name of Him
who is our Lord. Amen.
106
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 4, 2012

Will you please bow your heart with me in prayer? Our Heavenly Father, history has documented that
the most frequently cited source in the founding era of our great country was the Bible.
134
In 1777,
Congress desired to have a Bible printed under their care and their encouragement, and then they
ordered 20,000 copies of the Bible.
135
Patrick Henry who was an orator, a statesman, and the first
governor of the Commonwealth of Virginia declared that the Bible is worth all the other books that
have ever been printed.
136
President Andrew Jackson said the Bible is the rock on which our republic
rests.
137
And President John Adams reminded his fellow Americans the safety and prosperity of
nations ultimately and essentially depends on the protection and the blessing of almighty God. It is
clear that the Bible has had an incredible influence in shaping the history of our great country, the
United States of American. King Solomon wrote in the Holy Scriptures, Blessed is the nation whose
God is the Lord.
138
And so tonight, we seek your help, oh God, through daily prayer and daily Bible
reading that we may be able to guarantee for generations to come that we remain one nation under God,
indivisible, with liberty and justice for all, for the more we absorb the Scriptures and seek to live by its
precepts, we discover that God is able to accomplish amazing things for his purposes through our lives,
and so unitedly tonight we affirm our nations motto, in God we trust.

May truth and justice and righteousness prevail and flourish among our generations of Americans, and
may we seek to live justly and righteously and be zealous for those things that honor God. Thank you
for each member of our city council and their wonderful support staff. Infuse in them your wisdom and
your understanding. Give your solutions to every challenge and every opportunity that they face. We
invoke your irresistible presence and will to become the resource that you graciously grant to our
friends, the leaders we have elected. May proper decisions be made tonight to honor you and to benefit
each citizen and each guest in our beautiful city. This invocation we pray in the name of our wonderful

134
This claim is untenable and unsupported.
135
Congress never printed Bible. During the Revolutionary War, a printer, Robert Aitken, asked to publish a Bible under the
authority of Congress and to be commissioned by Congress to do so. Congress declined to do this but did recommend this
edition, in part because it was an instance of the progress of arts in this country. Gaillard Hunt, ed., Journals of the
Continental Congress, 1774-1789, vol. 23, (Washington D.C.: Government Printing Office, 1914), 574. Printing in this
country was important because of the British embargo. Aitken used the congressional recommendation to hawk his bibles
but, by his own account, they sold so poorly that he lost over 3,000 on the endeavor and could not get Congress to
reimburse him or buy the bibles. Robert Aitken to George Washington, June 9, 1790, George Washington Papers at the
Library of Congress, 1741-1799: Series 4, General Correspondence.
136
This is not a direct quote from Henry, it is a secondary quote about Henry, first published more than 90 years after his
death in William Wirt Henry, Patrick Henry: Life, Correspondence, and Speeches (1891), vol. 2, p. 519. Wirts source is a
Statement of George Dabney, MS. Letter to Mr. Wirt, Wirts Henry. The source has not been verified. The full quote
given is actually this: This book is worth all the books that ever were printed, and it has been my misfortune that I have
never found time to read it with the proper attention and feeling till lately.
137
No primary source provided or discernable. The earliest located source is Frederic William Farrar, History of
Interpretation: eight lectures preached before the University of Oxford in the year MDCCCLXXXV on the foundation of the
late Rev. John Bampton, page xxvii(MacMillian and Co., London, 1886),
http://books.google.com/books?id=kVX92B3TRkMC&printsec=frontcover&source=gbs_ge_summary_r&cad=0#v=onepag
e&q&f=false. According to the title page, Farrar was Archdeacon and Canon of Westminster and Chaplain in Ordinary to
the Queen. The Jackson quote is buried in a paragraph that begins, My main wish has been to show the true basis whereon
rests the sacredness of Holy Scripture It is because there is no Book and no Literature which can for a moment supply the
place of the Bible in the moral and spiritual education of mankind that I would do my utmost to save it from the injury of
false theories and impossible interpretations. Although Farrar cites several sources just a few pages earlier, no source is
provided for the deathbed quote by Jackson: That book sir, said the American President, Andrew Jackson, pointing to
the family Bible during his last illness, is the rock on which our Republic rests.
138
Psalm 33:12
107
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

Lord. Amen.
108
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

September 18, 2012

Will you please bow your heart with me in prayer? Our Heavenly Father, it was President George
Washington who said it is impossible to govern the world without God and the Bible.
139
In 1864
during the Civil War, the U.S. Congress approved engraving the phrase, In God we trust on the three
cent coin. Forty-four years later in 1908, legislation was passed to engrave In God we trust on all
U.S. coins. Then 47 years later in 1955, Congress passed a resolution that the phrase, in God we
trust would be printed on all coins and paper currency and one year later in 1956, in God we trust
became the national motto of our great country. And tonight as American citizens we boldly affirm as
a nation and as individual citizens, in God we trust.

And it is in this spirit that we pray this invocation tonight. As American citizens in this great nation we
enjoy the blessings of freedom given to us by God. And as such, we join our voices with President
Warren Harding who said, I implore the favor and the guidance of God in heaven. We pray
especially tonight that you would allow your protection and your power to strengthen all of our
American citizens who travel abroad. We pray especially for each of our American military personnel
and our American citizens who find themselves in areas where Islamic extremists are demonstrating
radically. Surround them with your safety. We pray you will bless all who work and serve us in our
city hall. Cause them to serve with the strength and the security of your invisible presence.

Bless our city council whom we have freely elected and our friends for whom we pray for by name
each day. May the members of our city council understand that they cannot properly discharge their
responsibilities or the tasks that have been assigned to them without your help, oh God. And tonight,
we ask you will crown this council meeting with your nearness. Give your divine guidance and your
direction in each of the thought processes of our leaders. May each decision that is made honor your
and be for the betterment of all of our citizens and guests. This invocation we pray in the name of our
personal Savior and Lord. Amen.

139
This is not accurate. There is no evidence recording that Washington said or wrote such a statement.
109
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

October 2, 2012

Will you please bow your heart with me in prayer? Our Eternal God, the founders of our great country,
the United States of America, stated over and over again that no nation can long endure without
morality and virtue in our citizens. A loss of principles and manners is the greatest threat to free people
and will cause its downfall more surely than any foreign enemy. Samuel Adams, the father of the
American Revolution said, While the people are virtuous they cannot be subdued.
140
And then he
added, The greatest security from enslavement in a country is morality among the people, desiring to
please their Loving Father and Great Creator, they live in accordance with his righteous standards.
141

Noah Webster, one of our well-known founding fathers said, The moral principles contained in the
Holy Scriptures form the basis of all of our civil constitutions and civil laws. And all the miseries and
evils men suffer from vice and crime and injustice proceed from neglecting the precepts contained in
the Bible.
142


So we ask that you would forgive us of our sins and our failures and place in our hearts a fervent desire
for your divine leadership to reign in our lives. Direct our paths in your way so that Your Will
becomes our desire and your way becomes our delight. In this season when our citizens are seeking
public offices in the political realm from the White House to the local city councils, may Your Will be
done. May every citizen perform their civic duty and go the polls and vote. May the power of your
presence bind us together as a people of one nation under God, and to this end, once again we boldly
affirm our nations motto, In God we trust. In the dignity of this city council meeting, we invoke
your divine wisdom and guidance to be upon our mayor and her colleagues and their support staff. May
righteousness fill city hall and fill these council chambers so that each decision will be a good decision
that will honor you and improve the lives of each of our citizens and each guest in our beautiful city.
This invocation we pray in our Saviors name. Amen.

140
This torrent [of levity, vanity, luxury, dissipation, and indeed vice of every kind] must be stemmed, and in order to do it
effectually, there must be an association of men of unshaken fortitude. While the people are virtuous they cannot be
subdued; but when once they lose their virtue they will be ready to surrender their liberties to the first external or internal
invader. How necessary then is it for those who are determined to transmit the blessings of liberty as a fair inheritance to
posterity, to associate on public principles in support of public virtue. If you are of my mind, and I think you are, the
necessity of supporting the education of our country must be strongly impressed on your mind Virginia is duly sensible of
the great importance of education, and, as a friend in that country informs me, has lately adopted an effectual plan for that
necessary purpose. If virtue and knowledge are diffused among the people, they will never be enslaved. This will be their
great security. Samuel Adams, February 12, 1779 letter to James Warren, The Writings of Samuel Adams, Vol. IV, 1778-
1802, p. 123-124 (Ed. Harry Alonzo Cushing)(GP Putnams Sons, 1908).
141
This is not found in the letter that contains Jones preceding quote, nor anywhere else. As stated in the previous footnote,
Adams does write something similar regarding public education, If virtue and knowledge are diffused among the people,
they will never be enslaved, but he never mentions a Loving Father, Great Creator, god or righteous standards of any of the
above. There is no evidence to suggest that Samuel Adams ever said this.
142
This somewhat truncated: But were we assured that there is to be no future life, and that men are to perish at death like
the beasts of the field; the moral principles and precepts contained in the scriptures ought to form the basis of all our civil
constitutions and laws. Noah Webster, History of the United State to which is prefixed a brief historical account of our
[English] ancestors from the dispersion at Babel, to their migration to America and of the Conquest of South America by
the Spaniards, 309 (Durrie & Peck, 1832). This is also not an exposition on Websters views of government, it is from
chapter 18 titled Advice to the Young, on the preceding page he writes, To young men I would recommend that their
treatment of females should be always characterized by kindness, delicacy and respect. The tender sex look to men for
protection and support. Females when properly educated and devoted to their appropriate duties, are qualified to add
greatly to the happiness of society, and of domestic life. Id. at 308.
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October 16, 2012

Will you please bow your heart with me in prayer? Our Heavenly Father, this is the last council
meeting before our all important election on Tuesday, November 6. In our own city, two council
members will be elected. All 435 members of the House of Representatives and one-third of our U.S.
Senate will be elected, and nationally we will elect our nations president. We humbly ask that people
of honesty and truthfulness and integrity will be elected. While hundreds of millions of dollars have
been spent in advertising this vital event, hundreds of thousands of hours of earnest prayer have been
invested by the people of God, our own citizens.

King Solomon was a political leader where peace and unprecedented prosperity was enjoyed by the
citizens of his nation. And he proclaimed the greatest political idea of all generations. It is written in
Holy Scripture and I quote, Righteousness exalts a nation, but sin is a reproach and an embarrassment
to any people.
143
And he further stated, The way of the Lord is strength for the upright and he who
walks in integrity walks securely. The righteous has an everlasting foundation and will never be
moved, and the memory of the righteous is blessed.
144
Many of our citizens and leaders have turned
from the path of righteousness in our lives and lifestyles. Infuse this ideal from King Solomon once
again into our public mind, and may it be practiced by our citizens.

We ask that you will cause every citizen to perform their civic duty and vote this season. Cause us to
elect leaders who will stand up for the clear standards that are expressed in the Bible, the Holy Writings
of God. May they stand firm for our freedoms to live by these standards. May we remember corporate
righteousness produces corporate benefits. Help us to recall our firm alliance on the protection of
divine providence and to give thanks for the freedoms and the prosperities that the people of our nation
enjoy. We pray for your continued help and guidance, our wise and loving creator.

Allow your infinite wisdom to be graciously bestowed on our city council tonight, these persons whom
we have freely elected. May your leadership be manifested in their lives and in their decisions as well
as the staff that support them. We seek your wisdom for the solutions to every situation that they
consider. Fill city hall and these council chambers with the peace and power of your eternal presence,
and cause every home and every citizen in Pismo Beach to feel the impact. This invocation we pray in
the strong name of our Loving Lord. Amen.




143
Proverbs 14:34
144
This is an amalgamation of several verses of Proverbs Chapter 10 from the Amplified Bible.
Proverbs, 10:29 The way of the Lord is strength and a stronghold to the upright, but it is destruction to the workers of
iniquity.
Proverbs 10:25 When the whirlwind passes, the wicked are no more, but the [uncompromisingly] righteous have an
everlasting foundation.
Proverbs 10:7 The memory of the [uncompromisingly] righteous is a blessing, but the name of the wicked shall rot.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

November 6, 2012
(City Manager Kevin Rice)

God Our Father,
145
creator of all,
146
thank you for our many blessings. Thank you for this beautiful day
on the Central Coast of California. Thank you for being able to live and work in the United States of
America. Thank you for our nations democracy where the supreme power rests in all the citizens
entitled to vote. Thank you for our friends and families. Thank you, God, for our city council
members who are the elected representatives of the people of Pismo Beach. As Veterans Day
approaches this weekend on November 11
th
, God, please remember to protect those currently serving in
the U.S. Armed Forces and who are in harms way. Also, please care for and protect all Americans
serving overseas and give their families strength. God, please hear our invocation. Amen.

145
This is typical of the Christian Bible, specifically the writings attributed to Paul. Paul begins most of his letters with a
greeting that references God Our Father. See Romans 1:7; 1 Corinthians 1:3; 2 Corinthins 1:2; Galatians 1:3; Ephesians
1:2; Philippians 1:2; Colossians 1:2; 2 Thessalonians 1:1; 2 Thessalonians 2:16; Philemon 1:3. See also James 1:27.
146
Even taken as a whole this phrase is sectarian Christian. See, 1 Corinthians 8:6 NLT, But we know that there is only
one God, the Father, who created everything, and we live for him. And there is only one Lord, Jesus Christ, through whom
God made everything and through whom we have been given life.; Malachi 2:10 Have we not all one Father? Did not one
God create us? Why do we profane the covenant of our fathers by breaking faith with one another?; Deuteronomy 32:6 Is
this the way you repay the LORD, O foolish and unwise people? Is he not your Father, your Creator, who made you and
formed you?
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

December 4, 2012

Will you please bow your heart with me in prayer? Our Heavenly Father, as grateful citizens of Pismo
Beach, we express to you our gratitude for the rain that has fallen the past three to four days upon our
city and region. Much of it fell so gently and soaked into the ground and as a result the air is clean and
the hills are turning green. Today, our city council concludes once phase of its administration. We
thank you for Ted Ehring who has served so faithfully the past eight years. He has given untiringly of
his knowledge and his skills and expended his efforts to better our city. Reward him and his lovely
wife Pat with your presence and your blessings in their lives and home. As a new council begins their
administration, we humbly seek your wisdom and guidance to be granted to each of them.

We remember history September 7, 1774, the first prayer that was prayed in Congress. History says
Washington was kneeling there and Patrick Henry and Randolph and Rutledge and Lee and John Jay
and to their side there stood many bowed in reverence, the patron puritans of New England who at that
moment had reason to believe that armed soldiers were wasting their humble households.
147
It was
believed that Boston had been bombarded and destroyed, but they prayed fervently for America, for
Congress, and for the province of Massachusetts Bay, and especially for the town of Boston. Who can
realize the emotions with which they turned imploringly to Heaven for divine interposition? Vice
President John Adams said it was enough to melt a heart of stone.
148
Included in that prayer were these
words: Be present, oh God of wisdom, and direct the council of this honorable assembly, and enable
them to settle all things on the best and surest foundations that order and harmony and peace may be
effectually restored and that truth and justice and religion and piety may prevail and flourish among the
people. Preserve the health of their bodies and preserve the vigor of their mind. And in 1789 the
newly inaugurated President George Washington gave a prophetic word at Federal Hall in New York
City. He declared that Americas prosperity and protection were dependent upon their adherence to
God, and later the political leaders of that young nation gathered at St. Pauls Chapel to pray and
commit the nations future to Gods purposes. That chapel is located at ground zero and miraculously
survived 9/11 virtually unscathed.
149
With such a national legacy, we boldly proclaim our nations

147
Jones appears to be describing an artistic rendition of this prayer and calling it history. See The First Prayer In
Congress, painted by T. H. Matteson and engraved by Henry Sadd (1848). Matteson was born 39 years after and painted
the work 74 years after the event he portrayed.
148
See footnote for April 19, 2011 prayer discussing this letter. Indeed much of Jones history of this 1774 prayer appears to
come from a fabricated letter. Compare the John Adams letter of September 7, 1774 on this link http://www.revolutionary-
war-and-beyond.com/john-adams-quotes-2.html which is mostly accurate until about two thirds of the way down, It had
excellent effect upon every body there. I must beg you to read the Psalm. At which point the letter is a fabrication as can be
seen from the original images at the Massachusetts Historical Society website,
http://www.masshist.org/digitaladams/aea/cfm/doc.cfm?id=L17740916ja.
149
This passage, beginning And in 1789 was lifted almost verbatim from www.WND.com from one of multiple stories
that essentially claim that 9/11 (and Superstorm Sandy and the recession) were Gods punishment to America for turning
our back on him (the main purpose of the articles appears to be to sell a documentary and book with this same hypothesis).
The WND paragraph reads:

In 1789, newly inaugurated President George Washington gave a prophetic warning at Federal Hall in New York
City. He declared that Americas prosperity and protection were dependent upon its adherence to God. Later, the
political leaders of the young nation gathered at St. Pauls Chapel to commit the nations future to Gods purposes.
That chapel is located at Ground Zero and miraculously survived 9/11 virtually unscathed.
It appears in at least six WND stories, including: Mark this Date for Potential Disaster, Isiah 9:10 Code suggests watchful
eye on specific day, (5/14/2012) http://www.wnd.com/2012/05/mark-this-date-for-potential-
disaster/#48Oo0hYMuHSaK151.99; Obama Fulfills Isaiah 9:10 Prophecy Again, (6/15/2012)
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS

motto tonight, in God we trust.

Gratefully, we gather in this public city council meeting. We have fully elected our friends, the mayor,
and her colleague to our city council to serve us. In obedience to Holy Scripture, we pray for each of
them tonight as in our daily prayers.
150
Good government is a principle that originated in the heart of
God, so cause each council member to sense the power of your invisible presence and allow your
divine wisdom to be given to them to make good and wise decisions, and may each decision honor God
and be for the betterment of all the citizens and guests of our beautiful city. This invocation we pray in
the name of our Lord. Amen.

http://www.wnd.com/2012/06/obama-fulfills-isaiah-910-prophecy-again/#uAUSY3sOIJRJIMBz.99; Sound off on
Whether God is Warning America: Share your thoughts on The Harbinger, Isaiah 9:10 Judgment, (8/9/2012).
http://www.wnd.com/2012/08/sound-off-on-whether-god-is-warning-america/#Ij9kjle8HD7K3W1C.99; No. 1 Christian
Author Defends Promoting his Book: Under Attack from fellow believers for interviews with certain programs,
(8/9/2012) http://www.wnd.com/2012/08/no-1-christian-author-defends-promoting-his-book/#16J3bHQW4i766Xe2.99;
Isaiah 9:10 Redux in Sandy Aftermath, (11/4/2012) http://www.wnd.com/2012/11/isaiah-910-redux-in-sandy-
aftermath/#azd6XoQLAghrwSlE.99; Isaiah 9:10 Linked to 9/11 Again!, (11/22/2012)
http://www.wnd.com/2012/11/isaiah-910-linked-to-911-again/#jPVzrQxfGwAM3dZM.99; Fall of New York Stock
Exchange: The 10
th
Harbinger?, (12/21/2012) http://www.wnd.com/2012/12/fall-of-new-york-stock-exchange-the-10th-
harbinger/#CQ6f7kgTTfZDJb70.99

And the church was not spared, the organ was badly damaged by smoke and dirt churned up by the falling twin towers.
Joe Kemp and Corky Siemaszko, Church Organ from St. Pauls Chapel damaged in 9/11 attacks returned in time for
Easter, NY Daily News, April 9, 2009.

150
1 Timothy 2:1-2.
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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
December 18, 2012
(Mayor asked for a moment of silence for those in Connecticut prior to invocation.)
Will you please bow your heart with me in prayer? Our Heavenly Father, it is Christmastime in our
city and in the surrounding community stores and shops are filled with carols and beautiful Christmas
music. Thank you that you have prospered so many that we may purchase gifts to those we love who
are so dear to us. Allow your favor to rest upon our business community, those who have planned so
earnestly and worked so diligently to sell their goods and services and then send sales tax and bed tax
to our city treasurer. For your favor we are grateful. Let us understand that the message of Christmas
is simple, and yet it is so wonderful. God wants to enter into all of lifes circumstances and God
chooses a beginning point for his wonder workings. To God, everybody is important.
Already we have bowed in a moment of silent prayer, but may we just continue tonight, Our Father,
and pray especially for those families in Connecticut whose school children and adult officials at the
school were so senselessly gunned down some days ago. May their grieving and sorrowing spirits be
brightened by your eternal presence. At this Christmastime we pray for all of our military personnel as
they serve the noble causes of freedom and liberty around the world. May each one who is deployed be
safe and secure, and may their loved ones here at home have Gods comfort and his presence as they
are separated one from another.
When our next city council meets, the Christmas lights will be out. Christmas trees will have faded.
Christmas ribbons will be forgotten and Christmas lights will be packed away, but the babe that was
born in Bethlehems manger will yet remain.
151
He will comfort when we are sorrowful. He will
provide meaning when lifes seasons seem so useless and so empty. He will bring light when the way
seems dark and he will provide joy when circumstances are grim, and long after the carols have been
hushed and long after the gift certificates have been cashed, the one whose birthday we celebrate will
continue to bring happiness and satisfaction.
Eric Howell is our newest city council member who begins his first full council meeting tonight. May
he sense your leadership in his new venture and may the spirit of unity that has characterized our city
council these past years continue among us in the days that are ahead. Tonight we invoke your divine
presence to fill city hall daily and to fill these council chambers tonight. Give your wisdom to our
mayor, her colleagues, and their support staff for the matters that are at hand tonight and in the future.
God, bless America. Protect our great country. Protect our citizens young and older. Protect every
citizen in Pismo Beach and protect the guests who visit our beautiful city. This invocation we pray this
holy Christmas season in the name of our personal Lord. Amen.
151
Luke 2:12
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January 15, 2013

Would you please bow your heart with me in prayer? Our Heavenly Father, this meeting tonight is the
first city council meeting of the New Year 2013. We pause tonight to thank you for the privilege to be
citizens of our great nation, the United States of America. The spiritual heritage of our country is a
continuing source of inspiration to us today. It was in the year 1800, when the construction of the U.S.
Capitol building was finished, and one of the first acts of Congress, was to approve the largest room in
the Capitol, the Hall of the U.S. House of Representatives as a church facility.
152
Each Sunday, services
alternated between the chaplain of the House of Representatives the chaplain of the Senate. U.S.
Senators, U.S. Representatives, and U.S. Presidents such as Thomas Jefferson and James Madison, and
John Quincy Adams regularly attended that church.
153
By 1867, the church at the Capitol had become
the largest church in Washington D.C. and one of the largest in the nation. Many of our forefathers
diligently honored God. All 50 of our U.S. state constitutions acknowledge God in their preambles.
For example, Connecticut begins by saying, We acknowledge with gratitude the good providence of
God, in permitting us to enjoy a free government. The constitution of Florida begins, We the people
of the state of Florida are grateful to Almighty God, for our constitutional liberty. And our own state
of California, our constitution begins by saying, We the people of the state of California, grateful to
Almighty God for our freedom, in order to secure and perpetuate its blessings do establish this
constitution. With such a spiritual heritage, as citizens of the 21
st
century we do not forget but we
boldly proclaim and affirm our nations motto, in God we trust.

Tonight we pray for our mayor, members of our city council, and their support staff. We invoke Gods
divine wisdom and courage to be freely given to each of them. May each determination that is made
bring esteem and righteousness toward God and may each decision bring justice and fairness and worth
to each citizen and each guest that visits our beautiful city. May your protection and your favor be in

152
The source of this story is inconclusive. A total of one sentence is devoted to the issue: The Speaker informed that
House that the Chaplains had proposed, if agreeable to the House, to hold divine service every Sunday in their Chamber.
Debates and Proceedings in the Congress of the United States (Washington: Gales and Seaton, 1853), p. 797, Sixth
Congress, December 4, 1800. No vote is recorded on the issue even though another issue was voted on that same day and
the vote recorded. See Id. at 799. No authorization, law, or act is mentioned, just the chaplains request.
153
Thomas Jeffersons attendance at Sunday services in the Capitol is misleading and can be traced to selective quoting of
Margaret Bayard Smiths descriptions of the events which show them to be less religious and more social:
...I have called these Sunday assemblies in the capitol, a congregation, but the almost exclusive appropriation of
that word to religious assemblies, prevents its being a descriptive term as applied in the present case, since the gay
company who thronged the H. R. looked very little like a religious assembly. The occasion presented for display
was not only a novel, but a favourable one for the youth, beauty and fashion of the city, Georgetown and environs.
The members of Congress, gladly gave up their seats for such fair auditors, and either lounged in the lobbies, or
round the fire places, or stood beside the ladies of their acquaintance. This sabbathday-resort became so
fashionable, that the floor of the house offered insufficient space, the platform behind the Speaker's chair, and
every spot where a chair could be wedged in was crowded with ladies in their gayest costume and their attendant
beaux and who led them to their seats with the same gallantry as is exhibited in a ball room. Smiles, nods,
whispers, nay sometimes tittering marked their recognition of each other, and beguiled the tedium of the service.
Often, when cold, a lady would leave her seat and led by her attending beau would make her way through the
crowd to one of the fire-places where she could laugh and talk at her ease. One of the officers of the house,
followed by his attendant with a great bag over his shoulder, precisely at 12 o'clock, would make his way through
the hall to the depository of letters to put them in the mail-bag, which sometimes had a most ludicrous effect, and
always diverted attention from the preacher. The musick was as little in union with devotional feelings, as the
place. Gaillard Hunt, ed., The First Forty Years of Washington Society, Portrayed by the Family Letters of Mrs.
Samuel Harrison Smith (Margaret Bayard) from the Collection of Her Grandson, J. Henley Smith, (New York, C.
Scribner's Sons, 1906), 14-15.
Smith describes the eventual change to a more solemn tone in the proceedings, but that is not how they began.
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abundance upon our leaders and each of our citizens. Thank you for hearing and responding to this
prayer of invocation, we pray it in name of our Loving Lord. Amen.



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PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS


February 5, 2013

Would you please bow your heart with me in prayer. Our Heavenly Father, as we read and reread the
writings of our nations founding fathers we are continually admonished to honor you and to live daily
in your righteous ways. Holy Scripture teaches us that righteousness exalts a nation, but sin is a
reproach and an embarrassment to any people.
154
It was George Washington, our first U.S. President
who said, Faith is absolutely vital to good government and to strong leadership. A moral nation
cannot be maintained without reliance on faith. Of all that leads to political prosperity, he said,
religion and morality are indispensible supports. Let us not suppose that morality can be maintained
without religion, for reason and experience both forbid us to expect that our national morality can
prevail in the exclusion of religious principle.
155
And in 1781 Thomas Jefferson, our third president
said, God who gave us life, gave us liberty. Can the liberties of a nation be thought secure if we
remove them from the only firm basis, a conviction in the minds of the people that their liberties area
gift from God.
156
So tonight it is in this spirit that we offer this invocation and once again we boldly
declare and affirm our nations motto, in God we trust.

Were exceedingly grateful for the bounties of Heaven that has preserved our great nation. We enjoy
peace and prosperity and power and wealth that is unknown by any other people on earth. And we
acknowledge your gracious guiding hand
157
in our great country and our beloved city. We pause
tonight to say thank you, that the little five-year-old boy who was held captive in an underground
bunker in Alabama for seven days was released unharmed yesterday. So many people throughout our

154
Psalm 14:34
155
Some of this quote comes from George Washingtons Farewell Address of 1796, Of all the dispositions and habits
which lead to political prosperity, religion and morality are indispensable supports And let us with caution indulge the
supposition that morality can be maintained without religion. Whatever may be conceded to the influence of refined
education on minds of peculiar structure, reason and experience both forbid us to expect that national morality can prevail in
exclusion of religious principle. The beginning of the quote is fictional.
156
Jefferson actually wrote this in two separate places more than 10 years apart.
1) The god who gave us life gave us liberty is from A Summary View of the Rights of British America (1774).
But let them [members of the parliament of Great Britain] not think to exclude us from going to other markets, to
dispose of those commodities which they cannot use, nor to supply those wants which they cannot supply. Still less
let it be proposed that our properties within our own territories shall be taxed or regulated by any power on earth
but our own. The god who gave us life gave us liberty at the same time: the hand of force may destroy, but cannot
disjoin them.
2) can the liberties Gift of God is from Notes on the State of Virginia, Query XVIII (1785). For in a warm
climate, no man will labour for himself who can make another labour for him. This is so true, that of the
proprietors of slaves a very small proportion indeed are ever seen to labor. And can the liberties of a nation be
thought secure when we have removed their only firm basis, a conviction in the minds of the people that these
liberties are the gift of God? That they are not to be violated but with his wrath? Indeed I tremble for my country
when I reflect that God is just: that his justice cannot sleep for ever . . .
157
Nehemiah 2:18, see also, 1 Chronicles 4:10 Jabez cried out to the God of Israel, Oh, that you would bless me and
enlarge my territory! Let Your Hand be with me, and keep me from harm so that I will be free from pain. And God granted
his request. The Christian bible continually references its god as Your Hand. See, e.g., Psalm 21:7-8 For the king trusts
in the Lord; through the unfailing love of the Most High he will not be shaken. Your hand will lay hold on all your
enemies; your right hand will seize your foes.; Psalm 74:10-11 How long will the enemy mock you, O God? Will the foe
revile your name forever? Why do you hold back your hand, your right hand? Take it from the folds of your garment and
destroy them!; Micah 5:9 Your hand will be lifted up in triumph over your enemies, and all your foes will be destroyed.;
Psalm 139:5, 10; Deuteronomy 3:24; Isaiah 26:11; 1 Kings 8:24; 2 Chronicles 6:15; Acts 4:29-30; Psalm 17:14; Job 1:11;
Job 10:7.

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nation united in their prayers and you responded so graciously. So tonight we invoke your blessing and
your wisdom to rest upon our mayor, the members of our city council and their support staff. Even
now, allow the power of your eternal presence and a new dimension of your divine enablement to enter
their thought processes to respond tonight to your guiding divine guidance. May the decisions that are
made tonight honor you and be for the betterment of our beautiful city all of our citizens and each of
our visiting guests. This invocation we pray in the name of our personal Lord. Amen.


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February 19, 2013

Our Heavenly Father, yesterday, Monday, February 18
th
, we as citizens of our great country celebrated
Presidents Day, honoring the birthdays of President George Washington and President Abraham
Lincoln, whose birthdays are only a few days apart this month. Both of these honorable men are
remembered as esteemed leaders. In his first inaugural address, President Washington opened with a
heartfelt prayer and said, and I quote, It would be impossible and improper to omit in this first official
Act my fervent supplications and prayers to that Almighty Being who rules over the Universe, who
presides in the Council of Nations, and whose providential aid can supply every human defect... Then
concluding his inaugural address in a strong spiritual tone, he called each citizen to remember and
acknowledge God saying, We ought to be no less persuaded that the favorable smiles of heaven can
never be expected on a nation that disregards the eternal rules of order and right, which Heaven itself
has ordained
158
unquote.

Tonight, we honor these great presidents of our nation. We also offer extreme gratitude for the gift that
God has given to our city these past nine years in the person of our City Manager, Kevin M. Rice. He
became our city manager March the first 2004. One of his primary responsibilities as city manager is
to deal with the citys annual budget and during his leadership our country and our county has faced the
greatest recession since the great depression. But Kevin Rice has managed our citys revenues and
helped Pismo Beach become the counties strongest city in terms of financial reserves. This gives such a
sense and a feeling of security to our leaders and to each of us as citizens. He has encouraged our
counsel to set mid-range and long-term goals. And these goal-setting sessions each year allows our city
to accomplish good things for our citizens on schedule.

Tonight is the final council meeting Kevin will conduct before his retirement and we say thank you
Kevin we deeply appreciate you, your leadership and your lifestyle, has enriched each of us. May gods
blessings continue to rest upon you. And, Our Father, we invoke your blessings upon all who work at
city hall. May each one sense the strength and the power of your enabling presence. Grant our mayor
and each counsel member and their support staff your divine direction may they receive your solution
for every challenge and need that they encounter tonight and in the future. May each decision that is
made honor you and benefit our citizens and benefit the guests that visit our beautiful city. This
invocation we pray in the name of our Loving Lord. Amen.













158
This was not really the conclusion of Washingtons address. This is from the fourth of seven paragraphsthe middle of
the address.
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March 5, 2013

Will you please bow your heart in prayer with me? Our Heavenly Father we thank you for our great
nation, the United States of America. We are grateful for every blessing and benefit that is continually
bestowed upon us as citizens. It was June 1954 when an amendment was made by the Congress to add
the words under God to our Pledge of allegiance to our nations flag. President Dwight D.
Eisenhower, who was president said, and I quote, In this way we are affirming the transcendence of
religious faith in Americas heritage and in its future. In this way we shall constantly strengthen those
spiritual weapons which forever will be our countrys most powerful resource in peace and in war. We
thank You tonight that we are one nation under God. And as such we reaffirm our nations motto in
God we trust.

Were so pleased that youve sent to us our new city manager, Mr. Jim Lewis. We welcome him whole-
heartedly. He has studied and applied himself, thus gaining knowledge. Now in addition to this we ask
that you would grant him your divine wisdom and your understanding and as such he will be prepared
to face each challenge and each opportunity in a positive and a rewarding manner. May it be evident
that he and our City Council work as a team with ease toward future progress in our city. We invoke
your blessings on all who work at City Hall. May our mayor and the members of the City Council and
their support staff each sense the strength and the power of Your enabling presence so that they may
receive your solutions to each item on tonights agenda and in the future. May you be honored and may
every citizen and each guest in our beautiful city be benefited. This invocation we pray in the name of
our Eternal Lord. Amen.




















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March 19, 2013

Will you again bow your heart with me in prayer? Our Heavenly Father, were reminded tonight of the
words that were prayed by president Abraham Lincoln in 1863 during the Civil War. Our beloved
country so greatly needed Your divine help and intervention and he prayed these words: It is the duty
of nations as well as men to owe their dependence upon the over ruling power of God. And to confess
their sins and transgressions and humble sorrow yet with assured hope that genuine repentance will
lead to mercy and pardon. And to recognize the sublime truth announced in the Holy Scriptures and
proven by all history, that those nations only are blessed whose God is the Lord.

And tonight our Heavenly Father, it is in this spirit that we pray this invocation. We do acknowledge
Your divine providence and we do desire to do Your will. We are extremely grateful for all of your
benefits: For life, and friends, and health, and prosperity, and your protection upon our beloved land. In
heartfelt humility we invoke your divine wisdom to be graciously bestowed upon every member of our
City Council. Grant solutions to each problem and each need so you, oh God, will be honored and we
will be benefited. We pray again the prayer of President Theodore Roosevelt who prayed a one-
sentence prayer, saying, We invoke the direction and the favor of almighty God for our guidance. We
declare our dependability and our responsibility and intention to pray daily for your leadership in the
lives and the decisions of each council member and their support staff. We ask you to fill City Hall and
these council chambers with the peace and the power of your divine presence. May each home and each
citizen and each guest feel the impact of your powerful presence in our city. Thank you for responding
to our united prayers. This invocation we pray in the name of our personal Lord. Amen.
a
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April 2, 2013

May I ask you to bow your hearts in prayer? Our Heavenly Father we thank you for the privilege to be
American citizens, with all the privileges and responsibilities that this entails. Our founding fathers
believed Americas government must be a government under God and wrote protection for the
freedoms we enjoy. History and biblical writings taught them that devastation always accompanies sin
and sinful lifestyles. However, Gods favor accompanies righteousness and anyone who lives without
compromise. These men knew that public prayer and public acknowledgement of God both reflect our
national character and promote our common good. Your continued favor has been graciously
demonstrated to our nation and to each of us since 9/11. On numerous occasions you have shown your
protection upon citizens of our great nation. Today we remember to say thank you and to ask your
continued blessings upon those who serve in the FBI and the CIA at home and abroad. And we boldly
declare our nations motto In God We Trust. We invite you to reign supreme in our nation and in our
city. May the light of your presence and the light of your power so avail that unrighteousness and no
strong hold of evil can ever prevail.

We give thanks for our mayor and her colleagues on our city council whom we have freely elected to
serve us. These are our friends. Were grateful for their leadership. And for their concern of our city of
Pismo Beach and for each of us as citizens. May your divine guidance be generously bestowed on them
tonight and this council meeting. Work through them and their gracious support staff that proper
solutions may be given for each item on tonights agenda. We invoke the direction and the favor of
Almighty God to be our guide. Long may our land be bright with freedoms Holy Light. Protect us by
thy might Great God our King. This invocation we pray in the name of our personal Lord. Amen.























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May 7, 2013

Our Heavenly Father, last Thursday, May 2, was celebrated in our nation as a National Day of Prayer.
Hundreds of thousands of citizens gathered in groups large and small. We united our voices in prayer
to God, to affirm a living faith in our eternal God, and to seek His favor and His blessings upon our
beloved country, the United States of America.

This annual event was established by a Joint Resolution of Congress, April 17, 1952, and signed into
law by President Harry Truman. This is not a political event, but a day that causes us to remember how
our Founding Fathers sought the wisdom of God for solutions to critical decisions. Recognizing our
sins and our shortcomings, we ask God to grant us His forgiveness. As well, we are aware that our
country needs a deep moral and spiritual renewal. So humbly we come before God, seeking His
guidance for each of our leaders, and His grace upon us as individual citizens.

It was President Franklin Roosevelt who declared, We cannot read the history of the rise and
development as a nation without reckoning the place the Bible has occupied in shaping the advances of
our republic. Where we have been the truest and the most consistent in obeying the Scriptures, we have
attained the greatest measure of contentment and prosperity. For the Bible says, Blessed is the man
who trust in the Lord.
159


Once again tonight, we boldly proclaim our nations motto In God We Trust, and we invoke your
divine wisdom upon each member of our City Council and their talented support staff. We ask you to
provide solutions to each challenge and each opportunity that they consider, in order that You may be
honored and we may be benefitted. Fill City Hall and these council chambers with the peace and the
power of your divine presence, and may each home and each citizen and each guest sense the impact of
your presence in our beautiful city. This invocation we pray in the name of our Loving Lord. Amen.

159
Jeremiah 17:7. This is passage is meant to be read with 17:5-6: Thus saith the LORD; Cursed be the man that trusteth in
man, and maketh flesh his arm, and whose heart departeth from the LORD. For he shall be like the heath in the desert, and
shall not see when good cometh; but shall inhabit the parched places in the wilderness, in a salt land and not inhabited.

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May 21, 2013

Our Heavenly Father, throughout history many nations have built monuments to record victories in
battle and peoples they have conquered. National monuments and symbols reflect the hearts of the
people, and identify what they believe is the source of their nations greatness and achievements. But
America, our country, is unique. Our monuments have no record of peoples conquered or nations
conquered, or the destruction of cities and empires. Our monuments contain the declaration that the
source of our birth, the source of our liberties, and the source of our greatness, is God.

Our nation was birthed by men who had a firm reliance upon almighty God, and particularly expressed
in our nations capital, Washington, D.C., is our nations faith in God. And it is inscribed on our
buildings and our monuments and our national symbols. In the great hall of the Jefferson building are
the Gutenberg Bible and a hand-copied giant Bible.

President Andrew Jackson declared, The Bible is the source upon which our republic rest.
160
And
many Bible quotations can be found on the ceilings and walls, such as Micah 6:8, which says, What
does the Lord require of you but to do justly and to love mercy and to walk humbly with thy God.
161

President Calvin Coolidge, our thirtieth U.S. President, said, The strength of our country is the
strength of its religious convictions. The foundations of our society and our government rest on the
teachings of the Bible. And tonight, we are most grateful for the national heritage left us by our
forefathers and our founders. And it is in this spirit that we boldly affirm our nations motto In God
We Trust.

As we pray tonight, we will not forget our fellow citizens in Oklahoma and elsewhere. They have
suffered because of the powerful tornadoes packing up to 200 mile an hour winds. Whole communities
have been destroyed. Many have lost loved ones and family members, and we pray earnestly and
sincerely tonight, Our Father, that you would cause them to experience your comfort and your love and
your powerful presence. Sustain them in this time of personal loss.

And tonight at this City Council meeting we ask that you would cause each of our friends whom we
have freely elected to serve on our City Council, that they would lead us on righteous paths. May they
manifest integrity of heart and transparency of spirit. Cause each council member that they would
receive a new dimension of your divine enablement. Function through them as you did through King

160
No primary source provided or discernable. The earliest located source is Frederic William Farrar, History of
Interpretation: eight lectures preached before the University of Oxford in the year MDCCCLXXXV on the foundation of the
late Rev. John Bampton, page xxvii(MacMillian and Co., London, 1886),
http://books.google.com/books?id=kVX92B3TRkMC&printsec=frontcover&source=gbs_ge_summary_r&cad=0#v=onepag
e&q&f=false. According to the title page, Farrar was Archdeacon and Canon of Westminster and Chaplain in Ordinary to
the Queen. The Jackson quote is buried in a paragraph that begins, My main wish has been to show the true basis whereon
rests the sacredness of Holy Scripture It is because there is no Book and no Literature which can for a moment supply the
place of the Bible in the moral and spiritual education of mankind that I would do my utmost to save it from the injury of
false theories and impossible interpretations. Although Farrar cites several sources just a few pages earlier, no source is
provided for the deathbed quote by Jackson: That book sir, said the American President, Andrew Jackson, pointing to
the family Bible during his last illness, is the rock on which our Republic rests.
161
Micah 6:8 - He has shown you, O mortal, what is good. And what does the Lord require of you? To act justly and to
love mercy and to walk humbly with your God. This quote is on one of the nine symbolic statues in the Library of
Congress representing the areas of knowledge. The statues are: Art, Commerce, History, Law, Philosophy, Poetry, Religion
and Science. The quote appears about the Religion statue.
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David of whom the Bible records, He led them according to the integrity of his heart, and he guided
them by the skillfulness of his hands.
162
We entrust our City Council and their support staff and each
citizen to your care and to your keeping, for your honor and our good tonight and in the future. This
invocation we pray in the name of our loving and gracious Lord. Amen.


162
Psalm 78:72
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June 4, 2013

Would you please join me in prayer? Our Heavenly Father, we are very mindful of our fellow citizens
who have suffered so deeply because of the powerhouse fires in southern California. Some have lost
their homes and all their belongings. Several of our courageous firefighters have been injured. Give
proper weather conditions we ask, so that these fires will be totally contained and extinguished quickly.
Allow your loving concern to bring peace and comfort to each heart and each life.

We express our thanks for all the manifold blessings and your continued favors that we receive, and it
is our desire to honor you in our daily lives. With great appreciation we boldly proclaim tonight our
nations motto In God We Trust. Solomon, the wisest king who ever ruled, penned in the Holy
Scriptures these words: Righteousness exalts a nation, but sin is a reproach and an embarrassment to
any people.
163
Tonight, we ally ourselves with the words of one our greatest statesmen, Daniel
Webster. He served as a United States Senator, and then later as Secretary of State. 150 years ago he
declared, If we abide by the principles taught in the Holy Bible, our country will go on prospering and
to prosper. But if we in our posterity neglect the instructions and the authority of the Bible, no man can
tell how sudden a catastrophe may overwhelm us, and bury all of our glory into profound obscurity.
164

So cause each of us to accept such wise instruction personally, and make it a part of our lives and our
lifestyles daily.

Tonight, in the dignity of this City Council meeting, we invoke your wisdom to guide our Mayor, her
colleagues, and their support staff. May they make wise decisions that will honor you and make better
conditions for the citizens and the guests who visit our beautiful city of Pismo Beach. Together with
your almighty help, combined with your divine wisdom, we are convinced that every challenge that
confronts our City Council will find your solution and be properly resolved. God grant this. Thank
you for hearing our united prayers. This invocation we pray in the blessed name in the wonderful name
of our Savior and Lord. Amen.

163
Proverbs 14:34
164
This quote is inaccurate. The true quote does not mention the Holy Bible or the Bible at all. It does mention
religious institutions, but only in conjunction with morality and our political constitution. The following is accurate:
if we maintain those institutions of government and that political union, exceeding all praise as much as it
exceeds all former examples of political associations, we may be sure of one thing, that, while our country
furnishes material for a thousand masters of the historic art, it will afford no topic for a Gibbon. It will have no
Decline and Fall. It will go on prospering and to prosper. But if we and our posterity reject religious institutions
and authority, violate the rules of eternal justice, trifle with the injunctions of morality, and recklessly destroy the
political constitution which holds us together, no man can tell how sudden a catastrophe may overwhelm us that
shall bury all our glory in profound obscurity. Should that catastrophe happen, let it have no history! Let the
horrible narrative never be written! Let its fate be like that of the lost books of Livy, which no human eye shall ever
read, or the missing Pleiad, of which no man can ever know more than that it is lost, and lost forever!
Daniel Webster, An Address Delivered before the New York Historical Society, February 23, 1852, available at
http://archive.org/stream/cu31924064123064#page/n5/mode/2up
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June 18, 2013

Would you please bow your heart with me in prayer? Our Heavenly Father, our nation, the United
States of America, has been bathed in prayer and respect for the teaching of the Bible since our earliest
beginnings. In 1787 at the Constitutional Convention, James Madison read from the Bible, Isaiah
33:22, The Lord is our judge, the Lord is our lawgiver, the Lord is our king; he will save us. And on
the basis of the Bible reading, he proposed the plan to divide our central government into three
branches: judicial, God our judge; legislative, God our lawgiver; and executive, God our king. He
discovered our model of government from the eternal governor.
165


In 1800 John Jay, the first Chief Justice of the U.S. Supreme Court, said, The most effective means of
securing the continuance of our civil and religious liberties is to always remember with reverence and
gratitude the source from which they flowed. Warren G. Harding, our 29th president, said, I implore
the favor and the guidance of God in Heaven. With these, I am unafraid and confidently face the
future.

And in June 1954 Congress added the words Under God to our Pledge. President Eisenhower said in
that day, In this way we reaffirm the transcendence of religious faith in Americas heritage and
Americas future. By this, we shall constantly strengthen the spiritual weapons, which forever will be
our countrys most powerful resource in peace and in war. And so we now boldly reaffirm our
nations motto In God We Trust.

Tonight, in the dignity of this public City Council meeting, we invoke your divine presence to fill these
council chambers. Give your wisdom generously to our mayor and her colleagues for the matters
placed on the agenda. With your omnipotent help and with your divine wisdom, guide them to think
clearly and wisely regarding each challenge that confronts them tonight. Grant to them your solutions
to properly resolve each matter that they consider. May you be honored and may each citizen benefit
from their decisions. God, bless and protect our beloved country and our beautiful city, and bless and
protect each citizen. This invocation we pray in the name of our Loving Lord. Amen.




165
This is simply false. Madison did no such thing. Historians are certain that this idea did not come from the Bible. It
came from Montesquieu who never mentioned or referred to the Bible in his discussion of the separation. See Barron
Charles Louis Joseph de Secondat Montesquieu The Spirit of the Laws, Book XI. The Federalist no. 47 is entirely devoted
to laying out the workings of this invaluable precept in the science of politics. James Madison, the author, wrote that no
political truth is certainly of greater intrinsic value, or is stamped with the authority of more enlightened patrons of liberty,
than that [of separation of powers.] He goes on to say [t]he oracle who is always consulted and cited on this subject is the
celebrated Montesquieu.

Furthermore this biblical passage does not separate power; it concentrates power in one being. This is exactly what the
Constitution sought to avoid. The founders thought that concentrating these [powers] in the same hands is precisely the
definition of despotic government (Thomas Jefferson, Notes on the State of Virginia, Query 13, 120-121, 1784) and that
such a concentration was the very definition of tyranny. The Federalist No. 47 (James Madison). Furthermore, the
founders thought that without separation of persons there cannot be a meaningful separation of powers. The Founders'
Constitution: Vol. I Major Themes 312 (Philip B. Kurland, Ralph Lerner eds., Liberty Fund)(2000).

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July 2, 2013

Will you please bow your heart with me in prayer? Our Heavenly Father, our hearts grieve when we
think of the 19 firefighters who died last Sunday fighting an out of control wildfire in Yarnell, Arizona,
near Phoenix. So many were young men, leaving wives and children. We pray your comfort to
strengthen and to sustain each of them and their loved ones who mourn such great loss. Bless and
protect our firefighters and our first responders everywhere.

July 4 will be a reality in just two days. All around our great country and in our city, millions of our
citizens will celebrate the great document we hold so dear to our hearts, the Declaration of
Independence. King George III of England declared the power of the divine right of kings. As such, he
held firmly the establishment of absolute tyranny over the 13 colony states. Judges were totally
dependent on his will, with a deaf ear to the voice of justice. Patrick Henry, the first elected governor
of Virginia, addressed the legislature with eyes uplifted, his hands aloft, and his whole soul burning
with divine inspiration,
166
he reminded them how God supernaturally delivered Israel from the tyranny
of Pharaoh and the Egyptian army.
167


He then declared, The same God still rules in Heaven, and is
watching from His throne the oppression of His people in America. He is still strong and mighty to
save.
168
And then he spoke so movingly, I know not what course others may take, but as for me, give
me liberty or give me death. Our Declaration of Independence clearly states that all men are created
equal and are endowed by their Creator with certain unalienable rights. Among them are life and
liberty and the pursuit of happiness, and that to secure these rights, governments are instituted.

When the document was read publicly in Philadelphia, great celebration followed. The Liberty Bell
rang loudly. It was called the Liberty Bell because on the words of that bell these words were engraved
from the Bible: Leviticus 25:12: Proclaim liberty throughout all the land.
169
The 56 signers declared
their integrity: We mutually pledge to each other our lives, our fortunes, and our sacred honor.

We are grateful tonight for Gods favor upon our country, and we are proud to be called Americans.
We invoke your richest favor and wisdom upon each member of our City Council as they lead our
citizens to honor God. May your paths become our chosen ways. We conclude this invocation with
words written by Samuel Francis Smith in 1831: My native country thee, land of the noble free, thy
name I love. I love thy rocks and rills, thy woods and templed hills, my heart with rapture fills, like
that above. Let music swell the breeze, and ring from all the trees, sweet freedoms song. Let mortals
tongue awake, and let all that breathe partake, let rocks their silence break, the sound prolong. Our

166
The text of Patrick Henrys Give me liberty or give me death speech (23 March 1775) is based on supposition. It comes
from a biography of Henry written by William Wirt (Sketches of the Life and Character of Patrick Henry (Philadelphia)
1836), who was three years old when Henry gave the speech. Wirt began to collect materials for Henrys biography in
1808, nine years after Henry died. He published the book in 1817, more than 15 years after Henry died. In the words of one
writer: There are no videotapes or films of that day, no audio recordings, not even a stenographers record of Henrys
words. We have nothing to guide us but the memories, years removed from the time, of those who were there. Jim Cox,
The Speech: It may not be the one that Patrick Henry so famously made, Colonial Williamsburg Journal, Winter 02-03,
available at http://www.history.org/foundation/journal/winter02-03/speech.cfm. And Wirts biography was a
romanticized, exaggerated, one-sided story. Id. A computer analysis of the linguistic style of speech shows it to be from
Henry Tucker, a source of Wirt and friend of Henry, but not of Henry himself. Id
167
This allusion does not appear in Wirt, or any reputable sources rendition of the speech. It appears to be invented.
168
Nor does this quote appear in Wirt, or any reputable sources rendition of the speech. It appears to be invented.
169
The Liberty Bell was forged in 1752 but didnt get its moniker until the 1830s when it was adopted by abolitionists.
Gary B. Nash The Liberty Bell, 36-38 Yale University Press, (2010).
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fathers God to Thee, author of liberty, to Thee we sing. Long may our land be bright, with freedoms
holy light, protect us by Thy might, great God our King. Amen.
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July 16, 2013
Dr. Paul Toms

Join with me please in a moment of prayer. Eternal God our Heavenly Father, we come before you
with thanksgiving this afternoon. Were grateful for the community in which we live. Were grateful
for all the beauties and the things that we enjoy. Were grateful for your provision for us and for our
families. Were grateful for every good and perfect gift
170
and we begin our meeting today with
thanksgiving for all your blessings. We seek today your hand of guidance
171
and direction upon us.

We thank you for policemen, for firemen, for our schoolteachers, for our doctors and our nurses, our
public servants, our families, for our children and youth, for all the good gifts that we have day by day.
We think of the great turmoil that goes on in so many parts of the world, even in our own country, and
here we are in quietness and peace, and were grateful for it.

Not only do you tell us to return thanks to you for your blessing but you ask us to give you petitions
and prayers.
172
And so we come to you today with our needs. This is a busy and significant time, these
are public servants that have come today to do work and activities and make decisions that will affect
the lives of our community and we commend each one of these people into your care.
173
Your Book
says, if any man lack wisdom let him ask of God, who giveth to all men liberally.
174
And so we need
decisions that will be made in keeping with Your Plan and Your Will, that will bless our community,
that will bless our young people, that will bless our families, that will help us all. So today we
commend this meeting into your care.
175
Thank you for public servants, thank you for people who
assume responsibility bless every person here today in this room and give us wisdom and guidance and
understanding. May the Joy of the Lord be our strength, may the Peace of God guide and keep us and
we will be grateful to you for every good and perfect gift that comes down through Christ, Jesus our
Lord
176
we pray. Amen


170
See James 1:17 (KJV) Every good gift and every perfect gift is from above, and cometh down from the Father of lights,
with whom is no variableness, neither shadow of turning.
171
See e.g., Isaiah 25:10, 66:14; Psalm 139:5 (NLT)
172
Philippians 4:6 Do not be anxious about anything, but in every situation, by prayer and petition, with thanksgiving,
present your requests to God.
173
See Acts 20:32 (KJV) And now, brethren, I commend you to God, and to the word of his grace, which is able to build
you up, and to give you an inheritance among all them which are sanctified.
174
James 1:5 (KJV) If any of you lack wisdom, let him ask of God, that giveth to all men liberally, and upbraideth not; and
it shall be given him.
175
See Acts 20:32 (KJV) And now, brethren, I commend you to God, and to the word of his grace, which is able to build
you up, and to give you an inheritance among all them which are sanctified.
176
See James 1:17 (KJV) Every good gift and every perfect gift is from above, and cometh down from the Father of lights,
with whom is no variableness, neither shadow of turning.
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August 20, 2013

Our Heavenly Father, in our great country we recognize that prayer is a gift from God to every human
being. It is a gift that permits us to come before God our Creator with heartfelt worship and request,
and with our deepest hopes. Prayer reminds us that when we bow our hearts or fall on our knees, we
are all equal in the eyes of the Living God.
177


In prayer we are assured that we are never alone in times of personal difficulty or individual suffering.
This is why Benjamin Franklin proposed that the Constitutional Convention of 1787 begin each day
with prayer and out of this group of public leaders who gave themselves to public prayer
178
was born
the Constitution of the United States on September 18,
179
1787, nearly 226 years ago. No legal
document ever written by man has done so much good for so many people and has become the hope
and the envy of every generation. Our founding fathers left us a legacy and a testimony to the role of
God in American history.

And so tonight we remember the civil strife in Egypt and Syria where innocent men, women, and
children are being killed every day by fellow citizens of opposing political persuasion. These needless
killings have continued for weeks and even months with seemingly no benefit to society. And so
tonight in prayer we pray that there may be a speedy cessation of these hostilities.

The Holy Scriptures strongly teach us, and I quote, Blessed is the nation whose God is the Lord.
180

And so today we once again give our personal affirmation to our nations motto, In God We Trust.
And in the dignity of this city council meeting, we invoke your Divine Wisdom and Guidance to be
upon our mayor and her colleagues as well as their support staff. May righteousness always fill city
hall. May righteousness always fill these council chambers. Then each decision will be a good
decision and this will honor god and improve the lives of each citizen and each guest in our beautiful
city. This invocation we pray in our Saviors name. Amen

177
Jeremiah 10:10 (NIV) But the LORD is the true God; he is the living God, the eternal King. When he is angry, the earth
trembles; the nations cannot endure his wrath. See also, Matthew 16:15 But what about you? [Jesus] asked. Who do
you say I am? Simon Peter answered, You are the Messiah, the Son of the living God.
178
Again, no prayer occurred at the Constitutional Convention Franklins motion failed. And if prayer had occurred, it
would not have been public prayerthe Convention proceedings were conducted in secret. See Edward J. Larson and
Michael P. Winship The Constitutional Convention: A Narrative History from the Notes of James Madison (2005).
179
The Constitution was signed on September 17, 1787, that is why Constitution Day is celebrated on September 17.
180
Psalm 33:12.
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September 3, 2013
Dr Paul Toms, no audio available.
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September 17, 2013

Will you bow your heart in prayer with me? Our Heavenly Father, our hearts have been deeply touched
by the torrential rains that have fallen in and around Boulder, Colorado. Bridges have been knocked
out and roads have been washed away and several people have drowned and hundreds are still missing.
Many have lost considerable possessions including their homes. And we ask that God would sustain
and comfort their hearts and their lives. And yesterday our nation was shocked as a gunman fired a
weapon killing 12 people and wounding many more before he himself was killed. So many families
and loved ones have been effected by this senseless action at the Washington D.C. Navy Yard. May
the families and the friends of the fallen and injured be strengthened by the power of your presence.

We join our hearts today with countless thousands of our citizens who are praying for a spiritual
awakening among the citizens of our country. Many of our peoples and our leaders have turned from
the path of righteousness in their own lives and lifestyles. King Solomon was a political leader where
peace and unprecedented prosperity was enjoyed by the citizens of his nation and he proclaimed the
greatest political idea of all generations, its written in Holy Scripture, it says: Righteousness exalts a
nation, but sin is a reproach and an embarrassment to any people.
181
He further stated, The way of
the Lord is strength for the upright.
182
And he concluded by saying that He who walks in integrity
walks securely.
183


Cause our leaders and our citizens to stand up for clear standards expressed in the Bible, the Holy
Writings of God. May they stand firm for our freedoms to live by these standards. Corporate
righteousness produces corporate benefits. So help us to refirmto recall what our forefathers called
our firm reliance on the protection of Divine Providence and give thanks for the freedoms and
prosperities that the people of nation enjoy. We pray for your continued help and guidance. Allow
your Infinite Wisdom to be graciously bestowed on our city council whom we have freely elected.
May your leadership be manifested in their lives and in their decisions as well as the staff that supports
them. We seek your wisdom for the solutions to every situation that they consider. Fill city hall and
these council chambers with the peace and the power of your eternal presence and cause every home
and every citizen in Pismo Beach to feel the impact. This invocation we pray in the strong name of our
Loving Lord. Amen.

181
Proverbs 14:34.
182
Proverbs 10:29.
183
Proverbs 10:9.
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October 1, 2013
Rajan Zed
[audio cut off] Glory of the Deity Supreme, who is inside the heart of the Earth, inside the life of the
sky, and inside the soul of the Heaven. May He stimulate and illuminate our minds.
184

Lead me from the unreal to the real, lead me from darkness to light, lead me from death to
immortality.
185

Fulfill all your duties, action is better than inaction, even to maintain your body you are obliged to act.
Selfish action imprisons the world. Act selflessly without any thought of personal profit.
186

Strive constantly to serve the welfare of the world. By devotion to selfless, one attains the supreme
goal of life. Do your work with the welfare of others always in mind.
187

May we be protected together. May we be nourished together. May we work together with great vigor.
May our study be enlightening. May no obstacle arise between us.
188

United your resolve, united your hearts, may your spirits be as one, that you may long dwell in unity
and concord. Peace, peace, peace be unto all.
189
OM. Thank you.
[The City Chaplain gave the pledge of allegiance, not Mr. Zed]
184
This prayer begins with the Gayatri Mantra, the most hallowed mantra of Hindu Scripture. See Sri Chinmoy,
Commentaries on the Veda, the Upanishads and the Bhagavad Gita, 87 (Aum Publications, 1996).
185
This is a quote from the Upanishads, the texts on which the Hindu religion is based. Like the Christian Bible, they
contain revealed truth and make claims about the nature of reality. This particular quote is from the Brihadranyaka
Upanishad, First Adhyaya, Third Brahmana, para. 27. See The Upanishads, Part 2, 83-84 (Max Muller, trans., 1879)
available at http://www.sacred-texts.com/hin/sbe15/sbe15054.htm.
186
This quote is from the Bhagavad Gita, 3.08-3.09. Lord Krishna, the eighth incarnation of Lord Vishnu, speaks these
words to Arjuna.
187
This is a quote from the Bhagavad-Gita.
188
This is a quote from the Upanishads, it appears several times in the Taittiriya Upanishad.
189
Rig Veda X, 191, 3.
135
PLAINTIFFS EXHIBIT 1: PRAYER TRANSCRIPTIONS
October 15, 2013
Our Heavenly Father, President George Washington spoke so clearly to his day and to our day when he
declared and I quote, No people can be bound to acknowledge and adore the invincible hand,
190
which
conducts the affairs of men more than those of the United States. So we offer to you tonight our God,
sincere gratitude and appreciation for your continued blessings and protection and bountifulness to our
country and to our citizens. We ask that you would continue to endow our intelligence community with
your favor and your skills as they seek each moment to protect each of us as citizens at home and
abroad. And tonight we unite our hearts as a grateful people and boldly affirm our nations motto, In
God We Trust.
Even now, we bow our hearts in true humility and ask your forgiveness for our personal sins and our
sins as a nation. Cause us to walk uprightly
191
and to pursue righteousness. The Bible teaches us from
the writings of King Solomon that Righteousness exalts a nation, but sin is a reproach and an
embarrassment to any people.
192
Tonight we invoke your invisible presence to hallow these city
council chambers. May your wisdom and your understanding be freely granted to our mayor, her
fellow council members and their support staff. We pray this to be the resource that becomes the
solution to each challenge and each opportunity we face.
We give you our thanks and our gratitude for the manner in which you continue to bless our city
financially. This past July, the transient occupancy tax, the tax our guests pay when they stay in our
hotel rooms again exceeded one million dollars in one month. Thank you for blessing our diligent
business people, which in turn has blessed our city treasury. God, bless the citizens and the guests of
our beautiful city of Pismo Beach. God, bless America and, God, protect America. This invocation we
pray in the wonderful name of our Loving Lord. Amen.
190
From Washingtons first inaugural address, but it actually said invisible hand, not invincible hand.
191
Proverbs 10:29.
192
Proverbs 14:34.
PROCLAMATION
A PROCLAMATION OF THE CITY COUNCIL OF THE CITY OF PISMO BEACH
HONORING DR. PAUL E. JONES FOR HIS 60 YEARS OF ORDAINED SERVICE
WHEREAS, Dr. Paul E. Jones graduated from Life Seminary with a Doctor of Theology
Degree in 1950; and
WHEREAS, Dr. Jones was ordained in Public Ministry in 1950; and
WHEREAS, Dr. Jones was Pastor of the Four Square Church in Canon City, Colorado for
seven years; Pastor in Portland, Oregon for three years, Pastor in Denver, Colorado for nine
years, and Pastor in Santa Fe Springs, California for four years; and
WHEREAS, Dr. Jones served as the Supervising Bishop for 16 years for the Southern
California District where he planted 125 new churches, resulting in 206 churches and 600
Pastors within the District; and
WHEREAS, Dr. Jones has served as the Assistant Protestant Chaplain for the Colorado State
Penitentiary for five years; Chaplain of the Civil Air Patrol for 15 years, retiring in rank as Lt.
Colonel; Board of Regents for Life Seminary for 10 years; and has served as the Pismo Beach
City Chaplin for the past five years; and
WHEREAS, Dr. Jones has been awarded the Honorary Degree of Doctor of Divinity and
recently honored with the Gold Ministerial Lapel Pin.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Pismo Beach
hereby honors Dr. Paul E. Jones for his 60 years of ordained service and for his outstanding
integrity and devotion to serving his fellow man.
Dated this 15
th
of June 2010
________________________
Mary Ann Reiss
Mayor
1
PLAINTIFFS' EXHIBIT 2: PROCLAMATION HONORING YEARS OF 'ORDAINED SERVICE'
C
cuuTer
Ci P 1
JoT
e
I
AGENDA
Ci ty
ofP i smo Beach
Counci l ClosedSessi on
I
CALLTOORDER
ROLLCALL
760 Matti eRoad
P i smo Beach Cali forni a
Mayor
Rei ss
Mayor
Mayor
P ro Tern
Counci lmembers
Rei ss
GonzalesGee
Hi ggi nbotham
Natoli Rabenaldt
I
P UBLI CCOMMENTS
Mayor
to ask for
publi c
comments
speci fi c
to thebelowli stedi tems
I
AGENDAI TEM S
I tem1 CONFERENCE WI TH LEGAL COUNSEL REGARDI NG P ENDI NG
LI TI GATI ON54956 9
Ci ty
ofP i smo Beachv Gragg Canyon
P artners LLC
I t i snoted that thecontentsofclosedsessi on
meeti ngsareconfi denti al and
exempt
fromdi sclosure
I
ADJOURNMENT
Affi davi t Date Ti meof
P osti ng
Date Februarv24 2005 Ti me 1030am
By
Lori
Gri gsby
CMC
Ci ty
Clerk
Ti tle Ci tyClerk
1
1
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
11
j
I
c
AGENDA
Ci ty
ofP i smo Beach
REGULAR
Ci t Counci l Meeti n
Tuesday
March1 2005 4 30
p
m
760
Matti
Road
P i smo Beach Cali forni a
I
CALLTOORDER
ROLLCALL
Mayor
Mayor
P ro Tem
Counci lmembers
Rei ss
GonzalesGee
Hi ggi nbotham
Rabenaldt Natoli
I NVOCATI ON Dr P aul Jones
P LEDGEOFALLEGI ANCE
Next Resoluti onNo R05009 Next Ordi nanceNo 0 0503
11
P RESENTATI ONS
I tem1 A AP roclamati onofthe
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beach
Honori ng
Kay
Lui s
Recommendati on
Mayor
to
present
P roclamati onto
Harry
Lui s
I tem1 B P roclamati on
regardi ng
Ameri canRedCrossMonth
Recommendati on
Mayor
to
present
P roclamati onto
Kelly
Van
Buren P ubli c
Support
Di rector
2
2
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
Counci l
Agenda
Tuesday
March1 2005
16
BUSI NESSI TEMS
AResoluti onoAhe
Ci ty
Cunci l of
tbe
Ci ty
ofP i smo Beach
Allocati ng
25000
from
th General Fund
Conti ngency
Account to FundtheNew
Arroyo
Grande
Hi gh
School P ool
I tem6A
Recommendati on Mr Starki eto
request fundi ng
and Counci l
adopt
Resoluti on
by
roll call vote
I tem6 B
I I
Re uest from
Mayor
P ro TernGonzales Gee
regardi ng appoi nti ng
a
Ci ty
Chaplai n
I
Recommendati on Di scussi onand Di recti on
17
CI TYMANAGERS REP ORT
I s
CI TYAHORNEYSREP ORT
19
COUNCI LSUBCOMMI TTEEREP ORTS
1 Area
Agency
on
Agi ng Naloli lGonzales Gee
2 Di nosaur CavesP reservati on
Soci ety Gonzales GeeHi ggi nbotham
3 Economi c
Vi tali ty Corporati on RabenaldVNatoli
4 P i smo BeachConference Vi si torsBureau Hi ggi nbotham
5 Fri endsofP ri ceHouse GonzalesGee
Hi ggi nbotham
6
I nlegratedWaste
Management Authori tyJP A Natoli
7 Mobi leHomeRent Stabi li zati on GonzalesGeeNatoli
8 SLOCounci l ofGovernments Rei sslGonzales Gee all
9 SLO
Regi onal
Transi t Authori ty Rei ss
10 Zone3Advi sory Commi tlee RabenaldtlNatoli alt
11 SLO
County Water Resources
Advi sory
Commi tlee Vacant
12 SLO South
County
AreaTransi t GonzalesGee
13 SLOAi r P olluti onControl Di stri ct Gonzales Gee Rei ss alt
14 Sceni c
Hi ghway Commi tlee Natoli
15 South
County
YouthCoali ti on
Hi ggi nbotham
Natoli alt
16 EOC
Hi ggi nbotham
17
Communi ty I mprovement Group
Gonzales GeeRabenaldt
18 VentanaFi reStati on GonzalesGeeHi ggi nbotham
1 g Cali forni aJoi nt P owersI nsurance
Authori ty Rei ss
5
3
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
Counci l
Agenda
Tuesday March1 2005
110
P ULLEDCONSENTAGENDA I TEMS
1
111
ADJOURNMENT
The Counci l meeti ng
wi ll
adjournby
11 00p m unlessafour fi fthsvoteoftheCounci l wi shesto conti nue
past
that ti me I fthe
meeti ng
i sadjournedat 11 00p m any remai ni ng agendai temswi ll beconti nuedto
the next
regular meeti ng
Affi davi t Date
llme
ofP osti ng
By
Date Februarv24 2005
Ti tle Ci tvClerk Ti me 4 30o m
General I nformati on TheCi ty
ofP i smo Beachmeets ontheFi rst
Tuesday
at 430
p
m andThi rd
Tuesdays
of eachmonthat 430
p
m unless
otherwi senoti ced
Counci l
Agendas
The
Ci ty
Counci l
agenda
i s nowavai lablefor
publi c
revi ewat
the Ci ty s websi te at wwwoi smobeachora and the Ci ty
Clerk s Offi ce 760 Matti eRoad P i smo Beach Cali forni aon
theThursday pri or
to thescheduledmeeti ng
Counci l Meeti ng Broadcasti ng
i s onChannel 20threeti mes a
day
Noti ceRegardi ng
Ameri canswi thDi sabi li ti esAct
I ncompli ance
wi ththeAmeri canswi thDi sabi li ti es Act i f
you
need
speci al
assi stanceto
parti ci pate
i nthi s
meeti ng please
contact the
Ci ty
Clerks Offi ceat773 7003at least 48
hours pri or
to the
meeti ng
to ensure that reasonable
arrangements
canbe made to
provi deaccessi bi li ty
to themeeti ng
28CFR35 102 35 104ADATi tleI I
6
4
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
P I SMOBEACH COUNCI LAGENDAREP ORT
SUBJECTfTlTLE
A RESOLUTI ON
OF THE CI TY COUNCI L OF THE CI TY OF P I SMO BEACH TO
ESTABLI SH THEP OSI TI ONOFCI TYCHAP LAI N
RECOMMENDATI ON
Counci l recei ves
report
fromCi ty Attorney
and
Ci ty Manager
and di scusseswhether i t i s
appropri ate
to establi shthe
posi ti on
of
Ci ty Chaplai n
EXECUTI VESUMMARY I
Counci l di rected staffto
agendi ze
adi scussi onofwhether to establi shthen
1
posi ti on
of
Ci ty Chaplai n F
resently
P i smo Beachhas no such
posi ti on
Ofthe s Cati forni a
ci ti es
respondi ng
to staffs
questi on
concerni ng
thesame
only
three ci ti es
responded
that
they
havea
Ci ty Chaplai n
Attachment 1
I n October of
every year
thestaff sends a letterto local mi ni sters and churchesaski ng
themto consi der volunteeri ng
to
gi ve
an i nvocati on
prayer
at the
begi nni ng
of
every
regularly
scheduled Ci ty
Counci l
meeti ng
P ri or to 2003 many
local mi ni sters
volunteered to
gi ve
an i nvocati on at the
Ci ty
Counci l
meeti ng Subsequent
to the
deci si on i n
the
Rubi nv
Ci ty
ofBurbankcase 2002 P i smo Beachhad approxi mately
two mi ni stersvolunteer to
gi ve
a
prayer
TheessenceoftheRubi nv Burbank casei s
that sectari an
i nvocati ons arei mproper
ataCi ty
Counci l meeti ng
Onthesthof
August
2003 the
Ci ty
Counci l of P i smo Beach unani mously passed
a resoluti on
prohi bi ti ng
i nvocati onsthat aresectari ani n nature Attachment2
I f theeffect ofestabli shi ng
a
Ci ty Chaplai nposi ti on
wouldbeto
preclude
other mi ni sters
from
gi vi ng
an i nvocati on then the Ci ty
i s
assumi ng
some undetermi ned legal
ri sk
Further si ncethe
Ci ty
has no hi stori cal
chaplai ncy programi nsti tuti ng
sucha
program
may
have
si gni fi cant
consti tuti onal
obstacles
especi ally
i n Cali forni as
li ti gi ous
cli mate
I f Counci l deci desto establi shtheposi ti on
ofCi ty Chaplai n
staff recommends that the
Counci l
appoi nt
ani ndi vi dual to fi ll the
posi ti on
for aone
year
term asthi swould
permi t
vari ous mi ni sters to volunteer for the
posi ti on
Ulti mately
theCounci l wouldi ntervi ew
candi datesand maketheselecti on
FI SCALI MP ACT
No cost asthi s
posi ti on
wouldnot bea
pai dposi ti on
OP TI ONS
1 Establi shthenew
Chaplai nposi ti onby
Resoluti on
2 Conti nue under current Ci ty procedures
Agenda
I tem
JJi
P age
1
128
5
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
ATTACHMENTS
1
Survey
ofCali forni aCi ti es
2 Resoluti on R0305 dated5
August
200
3 Resoluti on
P reparedby
Kevi n Ri ce
Ci ty Manager Meeti ng
Date March1 2005
I i f
1
Ci ty ManagerApproval
11 VJt I
Agenda
I tem 68
P age
2
129
6
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
SURVEY
Cities that Utilizea
Chaplain
January
25 2005
A
ffMk
1
x X
Burbank
X X
Chino
X X
Desert Hot Sp ngs
X
DiamondBm X
East PaloAlto
X X
El Monte
X X
Emeryville
X
X
Fort
Bragg
X
Fortuna
X X
GaIt
X X
Gilroy
X X
Glendora
X X
Gridley
X
X2
Hanford
X
X
Hollister
X
Irvine
X X
Kingsburg
X X
La
Quinta
X
Lodi
X X
130
7
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
[CITY]* [YES]* [NO]*
[Police
chaplain]*
*Plaintiff's have added this text, it appears in the heading
of the chart but cannot be read by the scanner. The police
chaplain heading is based on inference
A11lfdtl1e1JT
SURVEY
Ci ti esthat Uti li zea
Chaplai n
January
25 2005
l P
fi
t
t
I e
i I
i
LI
1
Marti nez X
Mi lpi tas
X
Monrovi a X X
I
I
Moreno
Valley
X
I
Murri eta X X
Newark X X
Oceansi de X X
P i co Ri vera X
P i nole X
P i ttsburg
X X
Reddi ng
X X
Redlands X X
Ri chmond X
Sali nas X
SanClemente X
SanDi mas X
SanLeandro X
SanMari no X
SantaClara X
SantaClari w X
131
8
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
[CITY]* [YES]* [NO]*
[Police
chaplain]*
*Plaintiff's have added this text, it appears in the heading
of the chart but cannot be read by the scanner. The police
chaplain heading is based on inference
SURVEY
Ci ti estbatUti li zea
Chaplai n
January
25 2005
hi ff X
Ii l
ft trI
r
r
t
i j
f
j
n
F r1
I 7i l
c1 t
I
l f lr
1
t
Y
14
t V
J
1
1
tJ h t
1
J
l
r
j
t
00
w i
SantaP aula X XFi re
Selma X
Si mi
Valley
X X
Solvang
I
X
St Helena X
Susanvi lle X
Temecula X X
Ti buron X
Vacavi lle X X
Whi ni er X X
Wi nters X
Woodland X X 3
Yuba
Ci ty
X X
132
9
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
[CITY]* [YES]* [NO]*
[Police
chaplain]*
*Plaintiff's have added this text, it appears in the heading
of the chart but cannot be read by the scanner. The police
chaplain heading is based on inference
Af1
tl 2
RESOLUTI ON
NO R03 53
ARESOLUTI ONOFTHECI TYCOUNCI LOFTHECI TYOFP I SMOBEACH
ADOP TI NGANI NVOCATI ONP OLI CYFORCI TYCOUNCI L
MEETI NGS
WHERr ASth8
Ci ty
o I P i smo BeachCounci l
lTi li leti ngscurreni ly
i ncludesani nvocati on
at the
begi nni ng
ofeachCounci l
meeti ng
and
WHERE AS theCourt i n Rubi n v
Ci ty
ofBurbank 2002 101 Cal
App 4lh
1194 held
that i nvocati ons whi ch ra sectari an I n nalure i e those whi ch
speci fi cally recogni ze
e
reli gi ous
fai th vi olate the establi shment clause under the Fi rst Amendment ofthe Uni ted
StatesConsti tuti on and
I
WHERE theCourt i n Rubi nv
Ci ty
ofBurbank
permanenUy enjoi ned the
Ci ty
of
Burbankfrom kli o
i ngly
and
i ntenti onally allowi ng
sectari an at
ci ty
counci l
meeti ngs
andorderedthe
ci ty
to advi se
anyoneconducti ng
apI llI yer as
part ofthe
ci ty
counci l
meeti ng
that sectari anprayersarenot
permi tted
and
WHEREAS the
Ci ty
ofP i smo Beachwi shesto
adopt
ani nvocati on
poli cy
whi chmeets
consti tuti onal I ltandards consi stent wi th the Court of
Appeals ruli ng
i n Rubi n v
Ci ty
of
Burbank
NOWTHEREFOREBEI TRESOLVED
by
the
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beach
asfollowa
1 The
Ci ty
Counci l
adopts
the
followi ng i nvocati on
poli cy
a The
Ci ty
Counci l
prohi bi ts the
offeri ng
ofani nvocati on that i s sectari an i n
ralure i e the
Ci ty
Counci l wi ll not
permi treferenca
to
anyparti culardei ty and
b 1he
Ci ty Counci l wi ll advi se
anyone wi shi ng
to offer
aQ
I nvocati on at
Ci ty
Counci l
meeti ngsthat i nvocati onsthat aresectari ani nnaturearenot
permi tted
P ASSEDANDADOP TED
by
the
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beach
by
moti on of
Counci lmember Rei ss seconded
by
Counci lmember Rabenaldt at the
regular meeti ng Ci ty
Counci l
Meeti ng
heldthi s511I
day
of
August
2003
by
the
followi ng
roll call vole
AYES
NOES
ABSENT
ABSTAI N
Counci lmembers Rei ss Rabenaldt GonzalesGee Natoli and
Mayor
Cresei one
None
None
None
l
ni to J resci one
Mayor
133
10
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
A1r I t1e
3
I I
Resoluti onROS
ARESOLUTI ONOFTHECI TYCOUNCI LOFTHECI TYOFP I SMOBEACH
ESTABLI SHI NGTHENONP AI DP OSI TI ONOFCI TYCHAP LAI N
Whereas the
Ci ty
Counci l ofP i smo Beach
acknowledges
the
blessi ngs
that thecreator
hasbestowedontheci ti zensofP i srtlo Beach and
Whereas the Ci ty
Counci l of P i smo Beachbeli eves i t i s
necessary
and
appropri ate
to
commenceevery
Counci l
meeti ng
wi thanon sectari an
prayer
BE I T RESOLVED
by
the
Ci ty
Counci l of t e
Ci ty
of P i smo Beach to
estrl
i 1i sh the
posi ti on
of
Ci ty Chaplai n
Sai d
posi ti on
wi ll benon pai d
and fi lledonaon
lear
term
Annually
Counci l wi ll i ntervi ewcandi dates for the
Chaplai n posi ti on
andl
i eleel
the
Chaplai nby voti ng
UP ON MOTI ON of Counci lmember seconded
by
Counci lmember
the
foregoi ng
Resoluti on i s
hereby approved
and
adopted
the
1st
day
ofMarch 2005
by
the
followi ng
rolecall vote to wi t
AYES
NOES
ABSTAI N
ABSENT
Mayor Mary
AnnRei ss
ATTEST
Lori
Gri gsby
CMCCi ty
Clerk
Agenda
I tem6B
P age
7
134
11
PLAINTIFFS' EXHIBIT 3: MARCH 1, 2005 P.B.C.C. MEETING AGENDA EXCERPT
EXPLAINING LEGAL DIFFICULTIES OF PRAYER AND CHAPLAINCY
MI NUTES
Ci ty
ofP i smo Beach
REGULAR
Ci t Counci l Meeti n
Tuesday
March1 2005 430
p
m
The
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beachmet thi s datei n a
regular
sessi on at 433
p
m i n the
Ci ty
Counci l Chambers 760 Matti e Road P i smo Beach Cali forni a wi th
Mayor
Rei ss
presi di ng
CALLTO ORDER
Mayor
Rei ss
ROLLCALL
P resent
Mayor
Mayor
P ro Tem
Counci lmembers
Rei ss
Gonzales Gee
Hi ggi nbotham
Rabenaldt Natoli
I NVOCATI ON was
gi ven by
Dr P aul Jones
P LEDGEOFALLEGI ANCE waslead
by Mayor
P ro TemGonzales Gee
Next Resoluti onNo R05009 Next Ordi nanceNo 00503
11
P RESENTATI ONS
I tem1 A AP roclamati onofthe
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beach
Honori ng
Kay
Lui s
Mayor
Rei ss
presented
aP roclamati onto the
fami ly
of
Kay
Lui s
P roclamati on
regardi ng
Ameri canRed CrossMonth I tem1 8
Mayor
Rei ss
presented
aP roclamati onto P hi l Harwi ck P ubli c
Support
Di rector
fortheAmeri can RedCross
2 P UBLI CCOMMENTP ERI OD
At thi sti me members ofthepubli c may
comment on
any
i tem NOTappeari ng onthe
agenda
except for Consent Calendar i tems Under StateLawmatters
presented
underthi si temcannot
bedi scussed oracted uponby
the
Ci ty
Counci l at thi sti me For i temsappeari ng
onthe
agenda
the
publi c
wi ll be i nvi ted to make comments at the ti me the i tem comes up
for Counci l
consi derati on At all ti mes
please
usethe
mi crophone
I n
response
to
your
comments theMayoror presi di ng
Counci lmember
may
Di rect stafftoassi storcoordi natewi th
you
ACounci lmember maystateadesi reto meet wi thyou
1
PLAINTIFFS' EXHIBIT 4: MARCH 1, 2005 P.B.C.C. MEETING MINUTES EXCERPT
INCLUDING OBJECTIONS TO PRAYERS AND VOTE ESTABLISHING CHAPLAINCY
RegularCi ty
Counci l
Meeti ng
Mi nutes
Tuesday
March1 2005 430
p
m
5
The
followi ng
ci ti zens
spoke
Lorrai neTrussler JoanKnowlton SteveAnderson DeeSannum RebeccaRei bel
Alan Kaloi an P aul Sawko Sheli a
Blakely
Jan McKi bbi n Jean Edlund Marti
Andersonall
spokeregardi ng
thi si tem
MOTI ON5 A
Moti on
by
Counci lmember Rabenaldt seconded
by Mayor
P ro TemGonzalesGee
to vote i n favor ofthe
posi ti on
ofthe
appellant by
Resoluti on R05009 Thi s
i temwas
approvedby
roll call vote P assed5 0
AYES Rabenaldt GonzalesGee Natoli
Hi ggi nbotham
Rei ss
NOES None
16
BUSI NESSI TEMS
I tem6A AResoluti onofthe
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beach
Allocati ng
25 000fromtheGeneral Fund Conti ngency
Account to FundtheNew
Arroyo
Grande
Hi gh
School P ool
Recommendati on Mr Starki eto
request fundi ng
andCounci l
adopt
Resoluti on
by
roll call vote
Mr Starki e
spoke
to Counci l
regardi ng
theAGHS
pool faci li ty
Mayor
Rei ssasked forcommentsfromthe
publi c
The
followi ng
ci ti zens
spoke
JohnFi sher
spokeregardi ng
hi s
approval
ofthi sresoluti on Bi ll
Worger
noted
the
pool
wouldbea
great
addi ti onto the
communi ty
MOTI ON6 A
Moti on
by
Counci lmember Rabenaldt seconded
by
Counci lmember
Hi ggi nbotham
to
approve
Resoluti on 05010
conti ngent upon
the use
agreement bei ng
revi ewed and
approved by
Counci l before release of
fundi ng
and that all other
agenci es
wi ll contri bute
up
to 225000 wi ththe
Ci ty
ofP i smo Beach
contri buti ng
thefi nal 25000 forAGHSto meet thei r
goal
of 250000forthe
faci li ty
Thi si tem
was
approvedby
roll call vote P assed50
AYES
NOES
Gonzales Gee Natoli Rabenaldt
Hi ggi nbotham
Rei ss
None
I tem6 B
Request
from
Mayor
P ro TemGonzalesGee
regardi ng appoi nti ng
a
Ci ty
Chaplai n
Recommendati on Di scussi onand Di recti on
2
PLAINTIFFS' EXHIBIT 4: MARCH 1, 2005 P.B.C.C. MEETING MINUTES EXCERPT
INCLUDING OBJECTIONS TO PRAYERS AND VOTE ESTABLISHING CHAPLAINCY
RegularCi ty
Counci l
Meeti ng
Mi nutes
Tuesday March1 2005 430p
m
6
Mayor
Rei ss askedfor
publi c
commentsregardi ng
thi si tem The
followi ng
ci ti zens
spoke
Don
Day spokeregardi ng
thi si temandfeels Dr Jonesi s
gi vi ng
back to the
communi ty
RoscoeMathi euspokeregardi ng
the
separati on
ofchurchandstateandthe
i nfri ngement
onthe
ri ghts
ofci ti zensandbeli evesi t s
i nappropri ate
MOTI ON6 B
Moti on
by Mayor
P ro TemGonzales Gee seconded
by
Counci lmember Natoli to
approve
Resoluti on 05011 establi sh the
posi ti on
of
Ci ty Chaplai n
and order
busi nesscardsandname
badge
Thi s i temwas
approvedby
roll call vote P assed
5 0
AYES
NOES
Gonzales Gee Natoli Rabenaldt
Hi ggi nbotham
Rei ss
None
17
CI TYMANAGERSREP ORT
Ci ty Manager
Kevi n Ri ce
reported
on the
followi ng
i tems Remi nd
everyone
regardi ng
theMarch9 2005500
p
m
Budget Workshop
and P ubli c
Heari ng
Mr
Ri cenotedthehardworkof
Randy
Bloomandhi sstaff
18
CI TYATTORNEYSREP ORT
Ci ty Attorney
Dave Flei shman noted that there have been
reports
of secret
meeti ngs
ofthe Counci l As far as Mr Flei shman i s concerned no BrownAct
vi olati onhasoccurredunder hi swatch
19
COUNCI LSUBCOMMI TTEEREP ORTS
1 Area
Agency
on
Agi ng
Natoli GonzalesGee
2 Di nosaur CavesP reservati on
Soci ety
Gonzales Gee
Hi ggi nbotham
3 Economi c
Vi tali ty Corporati on
RabenaldtlNatoli
4 P i smo BeachConference Vi si torsBureau
Hi ggi nbotham
5 Fri endsofP ri ceHouse GonzalesGee
Hi ggi nbotham
6
I ntegrated
Waste
Management Authori ty
JP A Natoli
7 Mobi leHomeRent Stabi li zati on GonzalesGee Natoli
8 SLOCounci l ofGovernments Rei ssGonzales Gee alt
9 SLO
Regi onal
Transi t
Authori ty
Rei ss
10 Zone3
Advi sory
Commi ttee Rabenai dtlNatoli aI t
11 SLO
County
Water Resources
Advi sory
Commi ttee Vacant
12 SLOSouth
County
AreaTransi t Gonzai es Gee
13 SLOAi r P olluti onControl Di stri ct Gonzales Gee Rei ss alt
3
PLAINTIFFS' EXHIBIT 4: MARCH 1, 2005 P.B.C.C. MEETING MINUTES EXCERPT
INCLUDING OBJECTIONS TO PRAYERS AND VOTE ESTABLISHING CHAPLAINCY
RegularCi ty
Counci l
Meeti ng
Mi nutes
Tuesday
March1 2005 430
p
m
7
14 Sceni cHi ghwayCommi ttee Natoli
15 South
County
YouthCoali ti on Hi ggi nbothamNatoli alt
16 EOC
Hi ggi nbotham
17
Communi ty I mprovement Group
Gonzales GeeRabenaldt
18 VentanaFi reStati on Gonzales Gee
Hi ggi nbotham
19 Cali forni aJoi nt P owersI nsuranceAuthori ty Rei ss
Counci lmember Natoli traveled to
Navajo
and
reported
onhi s
meeti ng
Counci lmember
Hi ggi nbotham
attended the EOC
meeti ng
and
reported
the
concernsof
budget
cutsand
eli mi nati ng
theCDBGGrants Shealso attendedthe
CVB
meeti ng
wi thMi keMaddenand
reported
onthe
upcomi ng
carshow
Counci lmember Rabenaldt
reported
that hewouldbeontheDave
Cogelton
radi o
show KVEC940 AMthi s
Thursday
at 4 00
p
m
Mayor
Rei ss attendedthe
Mayor
s
meeti ng they
di scussed
fundi ng
forci ti es
110
P ULLEDCONSENTAGENDAI TEMS
111
ADJOURNMENT
There
bei ng
no further busi ness Counci l
adjourned
at 7 09
p
m
ATTEST AP P ROVED
k
4
PLAINTIFFS' EXHIBIT 4: MARCH 1, 2005 P.B.C.C. MEETING MINUTES EXCERPT
INCLUDING OBJECTIONS TO PRAYERS AND VOTE ESTABLISHING CHAPLAINCY
http://www.meetup.com/San-Luis-Obispo-Atheists/
DATE: May 15, !1
"ontact: atheistsunite#.s$o%&mai$.com
Objection to Invocations at the City Council Meetings of Pismo Beach
Atheists 'nite# o( San Luis Obispo ob)ects to both the content an# intent o(
in*ocations p+ece#in& the main "ity "ounci$ meetin&s o( the "ity o( ,ismo -each. The
p+actice o( &i*in& in*ocations is inhe+ent$y base# in +e$i&ion, an# the cou+ts ha*e
+eco&ni.e# that &i*in& in*ocations at &o*e+nment meetin&s is $i/e$y to be p+e)u#icia$
to membe+s o( the community who #o not sha+e the (aith o( the pe+son &i*in& the
in*ocation 0(o+ e1amp$e, 2oyne+ *. 3o+sythe "ounty4. 5hi$e Atheists 'nite# o( San Luis
Obispo st+on&$y be$ie*es that in*ocations a+e inhe+ent$y #ismissi*e to non-+e$i&ious
pe+sons, the in*ocations use# in ,ismo -each #o not e*en (a$$ within the pe+missi*e
stan#a+#s cu++ent$y accepte# in $aw.
"ou+ts ha*e +u$e# that in*ocations can mention 67o#8 as $on& as they #o not
mention any pa+ticu$a+ &o#. This +u$e o( thumb is o(ten )o/in&$y +e(e++e# to as the
6#on9t say 2esus8 +u$e. 5hi$e D+. ,au$ 2ones, who nea+$y a$ways &i*es the in*ocations,
#oes +e(+ain (+om mentionin& 2esus speci(ica$$y, he +outine$y an# b$atant$y *io$ates the
spi+it o( the +u$e.
2ones (+e:uent$y uses e1p$icit$y "h+istian tu+ns o( ph+ase such as 6Ou+ Lo+# an#
Sa*io+8 an# 6Ou+ ;ea*en$y 3athe+.8 3o+ e1amp$e, at the Decembe+ !
th
meetin&, 2ones
state# 6the baby that was bo+n so $on& a&o in -eth$ehem9s man&e+ wi$$ continue to
b+in& happiness an# satis(action, (o+ his name is abo*e a$$ othe+ names, his +ei&n is
abo*e a$$ othe+ +u$e+s, his Lo+#ship is abo*e a$$ othe+ autho+ities, his wo+#s a+e abo*e
a$$ othe+ *oices, an# his t+uth is abo*e a$$ othe+ opinions . . .8 5hi$e 2ones #oes not
mention 2esus by name, we /now exactly which #eity he is +e(e++in& to an# that he is
p$acin& that #eity in a position o( p+imacy in this community with the tacit
en#o+sement o( its e$ecte# an# appointe# o((icia$s p+esent.
1/2
1
PLAINTIFFS' EXHIBIT 5: AUSLO MAY 15, 2010 LETTER TO P.B.C.C. OBJECTING TO PRAYER
These so+ts o( statements, which a+e +outine in 2ones9 in*ocations, p+i*i$e&e
"h+istian be$ie(s o*e+ those o( othe+ (aiths, an# o*e+ those without (aith. <n a##ition, a
(+e:uent theme o( 2ones9 is to state that the ci*ic o+#e+ is #epen#ent on +e$i&ious
(aith. This $atte+ type o( statement is hi&h$y e1c$usiona+y to the non-+e$i&ious as it
c$aims that peop$e o( (aith a+e the ones c+eatin& community = an# imp$ies that non-
+e$i&ious +esi#ents o( an# *isito+s to the "ent+a$ "oast a+e not a pa+t o( the
community. 5hi$e 2ones is entit$e# to his opinions, an# entit$e# to e1p+ess them,
&i*in& him a (o+um at these meetin&s constitutes an en#o+sement o( his speech by
the "ity "ounci$. The "ity "ounci$ cannot se+ious$y c$aim to be a secu$a+ bo#y when
meetin&s a+e +outine$y p+ece#e# by such e1c$usiona+y statements.
5e a$so conten# that an honest app+aisa$ o( in*ocations wou$# +eco&ni.e that
in*ocations a+e inherently #ismissi*e o( non-+e$i&ious pe+sons. To invoke is to ca$$
upon an autho+ity o+ )usti(ication (o+ one9s actions = an# e*en a &ene+ica$$y +e$i&ious
in*ocation imp$ies that the autho+ity o( the "ity "ounci$ #oes not #e+i*e (+om state
$aw an# the consent o( the &o*e+ne# but +athe+ (+om some so+t o( #i*ine man#ate.
-oth the 'nite# States an# "a$i(o+nia "onstitutions c$aim autho+ity on the basis o( the
&ene+a$ consent o( the &o*e+ne#. Autho+ity base# on #i*ine man#ate is not simp$y
unmentione#, it is e1p$icit$y +e)ecte#, most (amous$y in the Estab$ishment "$ause o(
the 3i+st Amen#ment. A+tic$e 1>, section 5 o( "a$i(o+nia9s "onstitution a$so (o+bi#s
$oca$ &o*e+nments (+om p+o*i#in& ai# o( any /in# to pa+ticu$a+ +e$i&ious o+&ani.ations
o+ c+ee#s.
The "ity "ounci$ o( ,ismo -each shou$# +eco&ni.e that thei+ autho+ity #e+i*es
(+om the &ene+a$ consent o( the community, not a #i*ine man#ate en*isione# by
pa+ticu$a+ membe+s o( that community. Atheists 'nite# ca$$s upon the "ity "ounci$ o(
,ismo -each to imme#iate$y cease usin& in*ocations at its meetin&s.
Since+e$y,
Atheists 'nite# o( San Luis Obispo
2/2
2
PLAINTIFFS' EXHIBIT 5: AUSLO MAY 15, 2010 LETTER TO P.B.C.C. OBJECTING TO PRAYER
1
PLAINTIFFS' EXHIBIT 6: FFRF AUGUST 15, 2010 LETTER TO P.B.C.C. OBJECTING TO PRAYER
2
PLAINTIFFS' EXHIBIT 6: FFRF AUGUST 15, 2010 LETTER TO P.B.C.C. OBJECTING TO PRAYER
3
PLAINTIFFS' EXHIBIT 6: FFRF AUGUST 15, 2010 LETTER TO P.B.C.C. OBJECTING TO PRAYER
4
PLAINTIFFS' EXHIBIT 6: FFRF AUGUST 15, 2010 LETTER TO P.B.C.C. OBJECTING TO PRAYER
MI NUTES
Ci ty
ofP i smo Beach
REGULAR
Ci ty
Counci l
Meeti ng
The
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beachmet thi sdatei na
regular
sessi onat
632
pm
i nthe
Ci ty
Counci l
Chambers760 Matti e
Road
P i smo
Beach
Cali forni a
wi th
Mayor
Cresci one
presi di ng
ROLLCALL
P resent
Mayor
Mayor
P ro Tem
Counci lmembers
I NVOCATI ON
Cresci one
Rabenaldt
Gonzales GeeNatoli
Rei ss
wasled
by
Dr P aul Jones
P LEDGEOFALLEGI ANCEwasled
by
Counci lmember Rei ss
Next Resoluti onNo R03 51 Next Ordi nanceNo 003 03
Atthi s ti me
members of thepubli c may
comment on
anyi temNOTappeari ng onthe
agenda
I t i s recommendedto keep
your
commentsto 3mi nutes UnderState Lawmatters
presented
under thi si temcannot bedi scussedor acted upon by
the
Ci ty
Counci l at thi sti me Fori tems
appeari ng
onthe
agenda
the
publi c
wi ll bei nvi tedto make commentsat theti me
thei temcomes
up
forCounci l consi derati onAtall ti mes
please
usethe
mi crophone
Marjori e
Elwood
spokeregardi ng
the
speci al
classthat Shell Beach
Elementary
School had
duri ng
the summermonths and
congratulated
theschool boardfor
promoti ng
suchan
outstandi ng
teacher and
program
Mi keRose
spokeregardi ng
thei ssueof the
meani ng of
major
andmi norfor
constructi on He would li ke a
good i nterpretati on
of the
Muni ci pal
Code
pertai ni ng
to thi si tem
1
PLAINTIFFS' EXHIBIT 7: AUGUST 5, 2003 P.B.C.C. MEETING MINUTES EXCERPT
ADOPTING A PRAYER POLICY AND THE POLICY ITSELF
Moti on
by
Counci lmember Rei ss seconded
by
Counci lmember Natoli
to
approve
Resoluti on No R03 52wi ththe
placement
ofthename
Dolli ver to another street wi thi n the
Ci ty
Staff i s to look at Shell
Beach Road as
possi ble
P CH name for the futureThi s i temwas
approvedbythe
followi ng
voi cevote
AYES
NOES
Gonzales GeeRabenaldt Rei ssNatoli
Cresci one
None
I tem6A
I tem6B
AResoluti onofthe
Ci ty
Counci l ofthe
Ci ty
ofP i smo Beach
Adopti ng
an
I nvocati on
P oli cy P rohi bi ti ng
Counci l
Meeti ng
I nvocati on
P rayer
that at i s
Sectari ani nNature
ieNo Referenceto
any
P arti cularGodi n
Li ght
of
Recent Court of
Appeals
Deci si oni nRubi nv
Ci ty
ofBurbank
Di etri ck
Fi le
111 1
Recommendati on
Adopt
Resoluti on
by
roll call vote
Chri sti neDi etri ck Ci tyAttorney gave
thestaff
report
Mi keRose
spokeregardi ng
hi s
opposi ti on
ofthi sresoluti on
Davi dTaub
spoke
i n
support
ofthi sresoluti on
ACTI ON P assed50
by
the
followi ng
moti on
MOTI ON6A
Moti on
by
Counci lmember
Rei ss seconded
by Mayor
P ro Tem
Rabenaldt to
approve
Resoluti on R03 53Thi s i temwas
approved
by
the
followi ng
roll call vote
AYES
Gonzales GeeRabenaldt Rei ss Natoli Cresci one
NOES None
Consi derati on and di scussi on
regardi ng
recrui tment of
Ci ty Attorney
pertai ni ng
to I n Houseor Contract hi re
Gri gsby
Recommendati on Di scussi onand Di recti on
A
lengthy
di scussi onensued
regardi ng
thi s i tem
ACTI ON P assed312
by
the
followi ng
moti on
MOTI ON 6B
7
2
PLAINTIFFS' EXHIBIT 7: AUGUST 5, 2003 P.B.C.C. MEETING MINUTES EXCERPT
ADOPTING A PRAYER POLICY AND THE POLICY ITSELF
A1r I t1e
3
I I
Resoluti onROS
ARESOLUTI ONOFTHECI TYCOUNCI LOFTHECI TYOFP I SMOBEACH
ESTABLI SHI NGTHENONP AI DP OSI TI ONOFCI TYCHAP LAI N
Whereas the
Ci ty
Counci l ofP i smo Beach
acknowledges
the
blessi ngs
that thecreator
hasbestowedontheci ti zensofP i srtlo Beach and
Whereas the Ci ty
Counci l of P i smo Beachbeli eves i t i s
necessary
and
appropri ate
to
commenceevery
Counci l
meeti ng
wi thanon sectari an
prayer
BE I T RESOLVED
by
the
Ci ty
Counci l of t e
Ci ty
of P i smo Beach to
estrl
i 1i sh the
posi ti on
of
Ci ty Chaplai n
Sai d
posi ti on
wi ll benon pai d
and fi lledonaon
lear
term
Annually
Counci l wi ll i ntervi ewcandi dates for the
Chaplai n posi ti on
andl
i eleel
the
Chaplai nby voti ng
UP ON MOTI ON of Counci lmember seconded
by
Counci lmember
the
foregoi ng
Resoluti on i s
hereby approved
and
adopted
the
1st
day
ofMarch 2005
by
the
followi ng
rolecall vote to wi t
AYES
NOES
ABSTAI N
ABSENT
Mayor Mary
AnnRei ss
ATTEST
Lori
Gri gsby
CMCCi ty
Clerk
Agenda
I tem6B
P age
7
134
3
PLAINTIFFS' EXHIBIT 7: AUGUST 5, 2003 P.B.C.C. MEETING MINUTES EXCERPT
ADOPTING A PRAYER POLICY AND THE POLICY ITSELF
MINUTES
City of Pismo Beach
REGULAR
City Council Meeting
Tuesday, May 19, 2009
The City Council of the City of Pismo Beach met this date in a regular session at 5:36 pmCity
Council Chambers, 760 Mattie Road, Pismo Beach California with Mayor Reiss presiding.
CALL TO ORDER: Mayor Reiss
1. ROLL CALL:
Present:
Mayor Reiss
Mayor Pro Tem Higginbotham
Councilmember Ehring
Councilmember Vardas
Councilmember Waage
Staff
Present:
Kevin Rice, City Manager
Dave Fleishman, City Attorney
Randy Bloom, Community Development Director
Emily Colborn, Deputy City Clerk
Greg Ray, Acting Public Works Director/City Engineer
Absent:
Dwayne Chisam, Public Works Director/City Engineer
George Edes, Administrative Services Director
City Council Regular Meeting http://pismobeach.granicus.com/MinutesViewer.php?view_id=...
1 of 8 10/21/13 2:08 PM
1
PLAINTIFFS' EXHIBIT 8: P.B.C.C. MEETING MINUTES EXCERPTS
WHERE STUDENTS ATTENDED
2. INVOCATION: Dr. Paul Toms
3. PLEDGE OF ALLEGIANCE: Dr. Paul Toms
At this time, Mayor Reiss recessed the City Council meeting to the
Closed Session previously convened at 4:30 p.m.
4. PRESENTATIONS
No items scheduled.
At 6:10 p.m. Mayor Reiss reconvened the City Council meeting and
announced no reportable action was taken at the Closed Session.
5. PUBLIC COMMENT PERIOD
Shell Beach Elementary G.A.T.E. Students: Jocelyn Reynolds, Palak
Patel and Leila Assal invited Council to attend the annual
G.A.T.E. Olympics (Gifted and Talented Education). The event will be
held Saturday, May 30, from 10:51 a.m. - 3:03 p.m. at Shell Beach
Elementary School.
Tom Murray representing SLO Green Build announced the Green
Retrofit Sweepstakes for residents of older homes in San Luis Obispo
County. Additional information is available at www.slogreenbuild.org.
Grover Beach Mayor John Shoals and Mayor Pro Tem Bill Nicolls
presented Council with the Grover Beach Rotary Annual Bowl-A-Thon
Fundraiser plaque in honor of their win during the 2009 City Council
Challenge.
Chet Hogoboom Manager of the SeaVenture Hotel invited Council to
attend the annual Volunteer Appreciation lunch in honor of the
beach clean up volunteers. The lunch is scheduled for Saturday, June
6th at 1:00 p.m.
6. CONSENT CALENDAR
Item 6.A: Clerks Report of Posting. The agenda of the regular May 19, 2009 City
Council meeting was posted on the City Council Chamber bulletin board on
May 14, 2009. (Frontella)
City Council Regular Meeting http://pismobeach.granicus.com/MinutesViewer.php?view_id=...
2 of 8 10/21/13 2:08 PM
2
PLAINTIFFS' EXHIBIT 8: P.B.C.C. MEETING MINUTES EXCERPTS
WHERE STUDENTS ATTENDED
MINUTES
City of Pismo Beach
REGULAR
City Council Meeting
Tuesday, February 2, 2010
The City Council of the City of Pismo Beach met this date in a regular session at 5:30 pmCity
Council Chambers, 760 Mattie Road, Pismo Beach California with Mayor Reiss presiding.
CALL TO ORDER: Mayor Reiss
1. ROLL CALL:
Present:
Mayor Reiss
Mayor Pro Tem Higginbotham
Councilmember Ehring
Councilmember Vardas
Councilmember Waage
Staff
Present:
Kevin M. Rice, City Manager
Dave Fleishman, City Attorney
Emily Colborn, City Clerk
Randy Bloom, Community Development Director
Dwayne Chisam, Public Works Director/City Engineer
George Edes, Administrative Services Director
Absent:
City Council Regular Meeting http://pismobeach.granicus.com/MinutesViewer.php?view_id=...
1 of 10 10/21/13 2:09 PM
3
PLAINTIFFS' EXHIBIT 8: P.B.C.C. MEETING MINUTES EXCERPTS
WHERE STUDENTS ATTENDED
None
2. INVOCATION: Dr. Paul Jones
3. PLEDGE OF ALLEGIANCE: Dr. Paul Jones
4. PRESENTATIONS
Item 4.A: Presentation by Elected Official(s), if any.
No presentations were given at this time.
Item 4.B: Employee of the Year Presentations. (Garcia)
The City Council read the proclamation into the record with Mayor Reiss
presenting the proclamation to Suzen Brasile, Mid-Manager of the Year
2009.
Item 4.C: Proclamation Declaring February 2010 as Grand Jury Awareness Month.
(Dorothy Schlitz)
The City Council read the proclamation into the record with Mayor Reiss
presenting the proclamation to Val McClure and Frank Fink.
Item 4.D: Proclamation Declaring the Month of February as Heart Healthy Month.
(Brasile)
The City Council read the proclamation into the record with Mayor Reiss
presenting the proclamation to Suzen Brasile, CVB Director.
5. PUBLIC COMMENT PERIOD
Marilee Hyman asked if the Council will report on their Goal Setting
session. Kevin Rice, City Manager announced that a detailed report
would be made at the next Council meeting on February 16, 2010.
Kiana Underwood from Destination Imagination thanked the Council for
their support of the Destination Imagination program. She reported on
their work with Special Education students and presented invitations to
the Council for their upcoming production of the "Three Piggy Opera."
City Council Regular Meeting http://pismobeach.granicus.com/MinutesViewer.php?view_id=...
2 of 10 10/21/13 2:09 PM
4
PLAINTIFFS' EXHIBIT 8: P.B.C.C. MEETING MINUTES EXCERPTS
WHERE STUDENTS ATTENDED
MINUTES
City of Pismo Beach
REGULAR
City Council Meeting
Tuesday, June 7, 2011
The City Council of the City of Pismo Beach met this date in a regular session at 5:30 amCity
Council Chambers, 760 Mattie Road, Pismo Beach California with Mayor Higginbotham
presiding.
CALL TO ORDER: Mayor Higginbotham
1. ROLL CALL:
Present:
Mayor Higginbotham
Mayor Pro Tem Vardas
Councilmember Ehring
Councilmember Reiss
Councilmember Waage
Staff
Present:
Kevin Rice, City Manager
David Fleishman, City Attorney
Emily Colborn, City Clerk
Jon Biggs, Community Development Director
George Edes, Administrative Services Director
Dwayne Chisam, Public Works. Director/City Engineer
Absent:
City Council Regular Meeting http://pismobeach.granicus.com/MinutesViewer.php?view_id=...
1 of 9 10/21/13 2:31 PM
5
PLAINTIFFS' EXHIBIT 8: P.B.C.C. MEETING MINUTES EXCERPTS
WHERE STUDENTS ATTENDED
None
2. INVOCATION: Dr. Paul Jones
3. PLEDGE OF ALLEGIANCE: Dr. Paul Jones
4. PRESENTATIONS
Item 4.A: Presentation by Elected Official(s), if any.
No presentations were given at this time.
Item 4.B: Proclamation for Hunter Norton. (Council)
The City Council read the Proclamation into the record with Mayor
Higginbotham presenting the Proclamation to Hunter Norton.
Item 4.C: Presentation by Destination Imagination. (Michelle Berlin)
Mike Liebo, Head of the Drama Department and Michelle Berlin, Drama
Coach, spoke regarding Destination Imagination and thanked the City
Council for all their continuous support. Students spoke regarding their
experiences while being a part of Destination Imagination.
5. PUBLIC COMMENT PERIOD
Laurie Nunez, owner/operator of Confusion Culinary mobile catering,
asked Council to review the prohibition of mobile catering within
the City.
Diane Cotter brought attention to a perceived blighted area on Dolliver
Street and Stimson Avenue.
Don Day requested that Council consider pulling Item 6.E: from the
Consent Agenda; a resolution approving the updated Engineers
Parcel/EDU Table, setting the water service special tax rate for FY 12 to
$181.50, and approving posting of said tax to the County Assessment
Roll.
6. CONSENT CALENDAR
City Council Regular Meeting http://pismobeach.granicus.com/MinutesViewer.php?view_id=...
2 of 9 10/21/13 2:31 PM
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PLAINTIFFS' EXHIBIT 8: P.B.C.C. MEETING MINUTES EXCERPTS
WHERE STUDENTS ATTENDED
1
PLAINTIFFS' EXHIBIT 9: PHOTO OF CITY CHAPLAIN WITH OFFICIAL NAMETAG, SEAL, ETC.
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PLAINTIFFS' EXHIBIT 9: PHOTO OF CITY CHAPLAIN WITH OFFICIAL NAMETAG, SEAL, ETC.
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Pamela Koslyn (State Bar #120605)
LAW OFFICES OF PAMELA KOSLYN
6255 Sunset Blvd., Suite 716
Hollywood, California 90028
Telephone: (323) 467-2200 Fax: (323) 648-8222
Email: pkoslyn@koslynlaw.com
Attorneys for PLAINTIFFS
FREEDOM FROM RELIGION FOUNDATION,
& DR. SARI DWORKIN
Superior Court of California
County of San Luis Obispo
FREEDOM FROM RELIGION
FOUNDATION, a Wisconsin corporation;
and DR. SARI DWORKIN, an individual,
Plaintiffs,
v.
CITY OF PISMO BEACH, a municipal
corporation; PISMO BEACH CITY
COUNCIL, the governing body of the CITY
OF PISMO BEACH; SHELLY
HIGGINBOTHAM, an individual in her
capacity of Pismo Beach Mayor; and PAUL
JONES, an individual in his capacity as
Pismo Beach City Chaplain; and DOES 1-
100, inclusive,
Defendants.
Case No.
PLAINTIFFS APPENDIX OF OUT-OF-
STATE AND OTHER AUTHORITIES
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Table of Contents
Historical References
Robert Alley, Public Education and the Public Good, William and Mary Bill of Rights
Journal, Summer 1995. .......................................................................................................................... 3
The Thomas Jefferson Encyclopedia, entry for National Prayer for Peace, available from the
Thomas Jefferson Foundation at http://www.monticello.org/site/research-and-
collections/national-prayer-peace.......................................................................................................... 8
Paul Boller and John H. George, They Never Said It: A Book of Fake Quotes, Misquotes, and
Misleading Attributions (Oxford University Press, 1989) .................................................................. 10
Max Farand, The Records of the Federal Convention of 1787, Volume 1 (Yale University Press,
1911) ....................................................................................................................................................... 15
The Founders' Constitution: Vol. I Major Themes (Philip B. Kurland, Ralph Lerner eds., Liberty
Fund) (2000) .......................................................................................................................................... 19
Thomas Jefferson, Notes on the State of Virginia, Query 13 (1784) ................................................ 21
James Madison, The Federalist No. 47............................................................................................... 23
Barron Charles Louis Joseph de Secondat Montesquieu, The Spirit of the Laws, Book XI.......... 20,27
Biblical References
The Precise Parallel New Testament (Ed. John Kohlenberger III, Oxford University Press)
(1995)...................................................................................................................................................... 33
Romans 1:7 ......................................................................................................................................... 36
1 Corinthians 1:3................................................................................................................................. 38
2 Corinthians 1:2................................................................................................................................. 40
Galatians 1:3 ....................................................................................................................................... 42
Ephesians 1:2 ...................................................................................................................................... 44
Philippians 1:2 .................................................................................................................................... 46
Colossians 1:2..................................................................................................................................... 48
2 Thessalonians 1:1............................................................................................................................. 50
2 Thessalonians 2:16........................................................................................................................... 52
Philemon 1:3 ...................................................................................................................................... 54
James 1:27........................................................................................................................................... 56
2
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
Volun1e 4 ! Issue 1
Public Education and the Public Good
RobertS. Alley
Repository Citation
RobertS. Alley, Public Education and the Public Good, 4 \Vtn. & Mary Bill Rts.]. 277 ( 1995 ),
http:// scholarship.law.wtn.edu/WI1lborj/vol4/issl/ 6
Cop}Tight c 199S by the authors. 'Ihis article is brought to you by the \Vilkun & Iv1ary Law School Scholarship Repository.
h t t p : / ~ lwl.tr;,hir.l,n, .w!.Led u/ wmbori
A1tide 6
3
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
PUBLIC EDUCATION AND THE PUB.LIC GOOD
Robert S. Alley"
I. INTRODUCTION
The year 1995 has brought a new leadership to the United States House
of Representatives that appears poised to initiate actions calculated to amend
the ReHgion Clauses of the First Amendm.ent and to offer legislation autho-
rizing some form of vouchers for parents to send children to private
schools.
1
That agenda; by Speaker Newt Gingrich, threatens the
fundamental principles of religious non-establishment and freedom espoused
by our eighteenth-century Founders., promotes a degradation of the nation's
public schools, and bodes ill for any sense of national identity that tran-
scends narrow sectarian divisions.
The new power in Washington espouses a general contempt for govern-
ment and for career politicians. This contempt contrasts sharply with the
views of the Founders whom Mr. Gingrich is so fond of quoting and recom-
mending for winter reading. James Madison was a consummate practitioner
of the art of politics. Ooventment was a genuine craft for the architect of
the Bill of Rights. As we listen to those current residents of the District of
Columbia who sneer at the government, a democracy that has bee.n our
guiding star for more than 200 years; one might wen ponder words from
one of Virginia's political leaders, Edmund Pendleton, who in a letter to
Madison urging the latter's election to the 1788 Virginia Ratification Con-
vention wrote:
[I]t is exceedingly indeed impossible, to make the
good people at large well Acquainted with the different
forms & combinations of Power necessary to constitute Gov-
ernment for the protection of liberty and property: and hence
they are exposed to impositions from designing men, and
particularly Of those in Opposition to Government> who have
the popular side, and by decrying powers as dangerous to
Professor of Emeritus, University of Richmond. Has taught religion at
the University of Richmond since 1963. Author of JAMES MADISON ON RELIGIOUS
ERTY (1985); THE SUPREME COURT ON CHURCH AND STATE (1988); SCHOOL PRAYER:
THE COURTt THE CONGRESS, AND THE FIRST AMENDMENT ( 1994), Recipient of 1994
Virginia ACLU Bill of Rights Award.
1
The Sayings of Speaker Gingrich; The House Leader on Teen Pregnancy, Bad
Schools, Volunteerijm and Saving the City, WASH. POST, Feb. 5, 1995. at C4.
277
4
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
316 WILLIAM & MARY BILL OF RIGHTS JOURNAL [Vol. 4: I
be held in this Assembly every morning before we proceed to business, and
that one or more of the Clergy of this City be requested to officiate in that
Service."
242
The Convention members briefly debated the issue and "after
several unsuccessful attempts for silently postponing the matter by
ing the adjournment was at length carried, without any vote on the mo-
tion. "
20
The Convention convened the foB owing morning, June 29th, for a
full day of business.
244
In spite of "historian" Gingrich, the delegates did not stop either a day
or an hour for fasting arid prayer at that . time or thereafter. It is shameful to
distort history intentionally to achieve some pious rub-off effect from a
event. The efficacy of prayer was not at issue for the leaders in
phia. They were men satisfied that they were endowed with minds with
which to think. Some were devout Christians, but those patriots in Philadel-
phia were not about the business of creating some form of a pious image of
then1selves. Of course there is no reason to suggest that because Madison
has no record of the Convention stopping for prayer during the entire
mer, prayer was rejected as a concept by individual members.
C. The Ten Commandments Hoax
In July, 1994, the organization Fairness & Accuracy in Reporting
(FAIR) pointed out that Rush Limbaugh had incorrectly attributed to Jan1es
Madison a quotation concerning the centrality of the Ten Commandments to
"American civilization."
245
Quickly rising to Limbaugh's defense were
several California residents who wrote letters to the Los Angeles Times. One
\vriter prefaced the alleged quotation with the following: ''Here {as quoted in
The .. Myth of Separation by David Barton) is precisely what Madison
said. "
246
The bogus quote followed: "We have staked the whole future of
American civilization, not upon the power of government, far from it. We
have staked the future of all of our political institutions upon the capacity of
mankind for self government; upon the capacity of each and all of us to
govern ourselves, to control ourselves, to sustain ourselves according to the
Ten Commandments of

What the writer, Rick Crowell, did not
ten us was that Barton cited as his only sources for those words two twenti-
eth century writers, Harold K. Lane in Liberty! Cry Liberty!/
48
and Fred-
1
_.
2
MADISON
1
DEBATES, supra note 64, at 182.
z.u !d.
244 ld.
245
Howard Rosenberg, Limbaugh Devotees Rush to his L.A. TIMES. July
11, 1994, at F 1.
246
Jd. at Fl.
247 !d.
148
DAVID BARTON, THE MYTH OF SEPARATION 308 (1992) (Citing HAROLD K.
5
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
1995) PUBLIC EDUCATION AND THE PUBLIC GOOD 317
erick Nyneyer in First Principles in Morality and Economics: Neighborly
Love and Ricardo's Law of Association.
249
Responding to the public hubbub, editors of The Papers of James
son, John Stagg and David Mattern, referred all inquirers to a letter dated
November 23, 1993t in which Mr. Mattern wrote concerning the alleged
quotation:
4
we did not find anything in our files remotely like the sentiment
expressed in the extract you sent us. In addition, the idea is inconsistent
with everything we know about Madison' s views on religion and govern-
ment, views which he expressed time and time again in public and in
private.H
250
This expert response has not dampened the ardor of those who
would have Madison affinn their own distorted version of American history.
Crowell accused Mr. Mattern of "revisionism at its worst.''
251
I offer here a
reconstruction of the convoluted trek of the words in question.
In citing David Barton's The Myth -of Separation as the source, Mr.
Crowell apparently missed the fact that Barton did not include the words,
''of all of our political institutions upon the capacity of mankind-for self-
govern.ment.H:;!s;z In a video tape Barton inserts "of all our political institu-
tions" but sti11 omits the "capacity of


This video version was
read into the Congressional Record by Representative Dannemeyer on
ber 7, 1992.
254
Barton's sources are two, or three, depending upon how you sort out his
confusion. Apart from citing the Lane volume of 1939, he offers as his oth-
er source Frederick Nyneyer's First Principles in Morality and Economics:
Neighborly Love and Ricardo's Law of Association.
155
In fact, his source
appears to be an article entitled Neighborly Love and Ricardo's Law of As-
sociation.256 Far from appearing in a source by Nyneyer, the alleged quote
is found in the latter article and drawn H[f]rom the 1958 calendar of Spiritu-
al Mobilization.H
257
Barton's attempted documentation becomes exponen-
tially more curious. He seems to have no clue as to his sources. When ap-
proached about his mythical additions to Jefferson's letter to the Danbury
LANE, LIBERTY! CRY LIBERTY 32-33 (1939)).
2
.t
9
FREDERICK. NYNEYER, FIRST PRINCIPLES IN MORALITY AND ECONOMICS:
BORLY LOVE AND RICARDO' S LAW OF ASSOCIATION 3i (1958}.
250
Letter from David Mattern to Gene Garman, Nov. 23, 1993. A copy of this letter
was supplied to the author by Mr. Mattern, current editor of The Papers of James Mad-
is on.
251
Rosenberg, supra note 245, at F 1.
m supra note 248, at 155.
253
Barton, supra note 82, at E3072.
2
S4 Jd. at E3071.
m BARTON> supra note 248, at 308.
256
4 PROGRESSIVE CALVINISM 31 (1959).
2s1 Id.
6
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
318 W!.LLIAM & MARY BILL OF RIGHTS JOURNAL [VoL 4:1
Baptists, he deleted the references in a later edition of his tape.
158
The connection between the Ten Commandments and James Madison
has been variously advanced, by numerous commentators from the political
right over the past several decades. In I 964
5
Clarence Manion wrote:
As Nfadison stated in the {T]he our entire politi-
cal experiment swings upon our capacity to govern ourselves
according to the moral law. . . . The only people who can
afford the great luxury of a civil government strictly limited
by law are those people who recognize and are willing to
live by their natural, obligations and responsiw
bilities under the Ten Commandments.
259
There is nothing in The Federalist Papers remotely resembling what is ar ..
gued by Manion. Madison never mentioned the Ten Commandments in any
of The Federalist essays. There are, however, two points to be made. First,
Manion, while claiming to cite The Federalist Papers, does not have the
temerity to quote Madison. Second, while Manion espouses generally the
same sentiment about the Ten Commandments as does the Barton material,
the references to the Decalogue are utterly different from the Barton version.
Proving that a quotation does not exist is a daunting task. If you cannot
find it in any extant manuscripts or collections of Madison's works, just
how does one prove it will not tum up in someone,s attic tomorrow? Of
course you cannot. That is why the Madison editors were carefu) in how
they phrased their response. But, after all, it is incumbent solely upon the
perpetrators of this myth to prove it by at least one citation. This they can-
not do. Their style is not revisionism, it is anti-historical.
We likely have not heard the last of this nonsense, but it is important to
press the new media frauds to document what they claim. Because they can-
not do so in most instances, time may ultimately discredit the lot of them.
IV. THE SUPREME COURT ON CHURCH AND STATE! 1940-1960
Madison's death in 1836 marked the end of the era of the Founders. He
was the last living member of the 1787 Constitutional Convention. As evi-
denced by correspondence late in Madison's life, the popular perception of
the nation was, by the 1830s, frequently phrased in terms of a Protestant
hegemony.
260
In fact, if not in law, the huge Protestant majority enforced a
25
a See supra text accompanying notes 233-36.
l
59
CLARENCE MANION, THE CONSERVATIVE. AMERJCAN 197 (1964). Manion
utes these sentiments to Madison in Federalist No. 39.
260
Letter from James Madison to Reverend Jasper Adams (circa 1834), in 9 THE
WRITINGS OF JAMES MADISON, supra note 73, at (internal references of this let-
7
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
National Prayer for Peace Thomas Jefferson's Monticello http://www.monticello.org/site/research-and-collections/national ...
1 of 2
A number of sources attribute a "National Prayer of Peace" to Thmnas J efferson

Almighty God, Who has given us this good land for our heritage; We humbly beseech Thee
that we may always prove ourselves a people mindful of Thy favor and glad to do Thy will.
Bless our land with honorable ministry, sound learning, and pure manners.
Save us fro1n violence, discord, and confusion, from pride and arrogance, and from every evil
way. Defend our liberties, and fashion into one united people the multitude brought hither
out of many kindreds and tongues.
Endow with Thy spirit of wisdom those to whom in Thy N arne we entrust the authority of
government, that there may be justice and peace at home, and that through obedience to Thy
law, we 1nay show forth Thy praise among the nations of the earth.
In time of prosperity fill our hearts with thankfulness, and in the day of trouble, suffer not
our trust in Thee to fail; all of which we ask through Jesus Christ our Lord, Amen.
This prayer was not written or delivered by Thomas Jefferson. It is in fact from the 1928 United States
Book of Common Prayer. Explanations of the 1928 revision of the Book of Common Prayer make no
mention of an earlier source for the prayerJf l (#footnote J t.me jnrq) C# is identified simply as "For
Our Country." 12 ] ( #footnote:.. 7t1lls:r?) i.Jf noh'L)
Interestingly, although we can find no evidence that this prayer has a presidential source, it was used by
a subsequent president in a public speech. Several months after his 1930 Thanksgiving Day Address as
Governor of New York, it was pointed out that Franklin Delano Roosevelt's speech bore a striking
resemblance to the very same prayer discussed above. b.l (t: footnotea ..
Ultimately, it seems unlikely that Jefferson would have composed or delivered a public prayer of this
sort. He considered religion a private matter, and when asked to recommend a national day of fasting
and prayer, replied "I consider the government of the United States as interdicted by the Constitution
from inter meddling with religious institutions, their doctrines, discipline, or exercises ... "W
1 z
FURTHER SOURCES
Fake History. "Thomas .Jefferson an(l a Praver for Peace (http:/ /fakehistorv.wordr ress.com/20ll/02/o6/thomas-
ief ersc n.:JJ.llCL .. a .. m ..
Sheridan, Eugene R. Jgf/j;rSQ]J.'s ReligiO.LL.Jhttp: / / v. IUW.t.uorldcut.orgjocl:l.'N.tJ6fi;?78) Charlottesville, Va.:
Thomas Jefferson Foundation, 1998.
FOOTNOTES
10116113 3:17PM
8
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
National Prayer for Peace Thomas Jefferson's Monticello http://wwvv.monticello.org/site/research-and-collections/national .. .
2 of 2
D.D., The New American Prayer Book: Its History and Contents (New York:
Macmillan Company, 1929), Chapter VIII. The New Prayer Book: Enrichment. Available online
at http: I I c.lnglicanhistorv.org/bep/ chorlev19':>91 o8.htrn1 (http:/ /angiicanhist orv.org/bcp/ cbor1evl9? q

2 . Cli'o(l,]iJ. D[;'fl!.]Jlttial:15f'rayer, 35, available online at httv.J.L:i!l..tus.angliean.org/resourees/hep/l928
fPrav&Th 'lgks.htnl (bttn: I /iustus. andiean.org/ resources/bcp/19::.. 8/Prav&'Iha nks.htm) .
3. TIME, February 23, 1931. Available online at http://ww\v.time.eom
(http:Lfvv, .. v-v .time.ec m/ time/mm;azin e/articl e
L9_,_9J.ZL!l3i!.33.g,_Q.L.b_t!JJJl .
4 . cllho:ml&iJleffi1rto'omnto Reverend Samuel Miller, 23 January, 1808. Ford, (h tt p:/
L!iilt' ions/ short ist2_ 9:17 4-176.
TAG TH!S
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D!SCUSS!Oi !
An excellent read on the topic of Jefferson and religion can be found in an offering by Daniel
L. Dreisbach: Thomas Jefferson and the Wall of Separation Between Church and State.
1
,Jeff \Vinkl er (/sitc / bl og-and-comnJunit v/ uscrs/kff-wink! er) - Jefferson/Monticello Enthusiast
February 8, 2011, 7:23pm
This prayer actually first appeared in the 1885 Book of Common Prayer where it was added
at the suggestion of a committee appointed to revise it in 1880. A commission appointed in
1913 suggested further revisions, and these were incorporated into the version printed in the
1928 edition.
The author of the original prayer, according to Christopher L. Webber (Give Us Grace: An
. Anthology of Anglican Prayers, [Harrisburg PA, 2004], p. 318), was George Lyman Locke
(1835-1919).
1 I did a piece on this at FaJ<el:liJ.QI'Y
L\Dsl:.:.l2.l1ll.:.t!.:::ful'.:ll . llfi"J_l .
Vsit ;&.log-and-romnnmitv/t ls "rs/sbh) - Jefferson/Monticello Enthusiast
February 7, 2011, 6:39pm
ADD COMMENT
Login i(m=node9 or register (/1iSCr/n:mic;t er?de.stination=node.,,:"!F1169''62:1COiilll lf' IJt-formj to post
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10/16113 3: 17 PM
9
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
10
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
126 They Never Said It
vetius accurately enough, and there was no desire on Evelyn
Hall's part to mislead anybody.
2
2o
~ Washington, George (1732-1799)
ANTI-JEWISH QUOTE "They work more effectively against us
than the enemy's armies. They are a hundred times more
dangerous to our liberties and the great cause we are engaged
in. It is much to be lamented that each state, long ago has not
hunted them down as pests to society and the greatest enemies
we have to the happiness of America-The Jews."
This quote, popular among American anti-Semites, is a dis-
tortion of a statement Washington once made about specula-
tors in currency during the American Revolution. "This
tribe of black gentry," he wrote, "work more effectually
against us, than the enemy's arms. They are a hundred times
more dangerous to our liberties, and the great cause we are
engaged in. It is much to be lamented, that each State, long
ere this, has not hunted them down as pests to society, and
the greatest enemies we have to the happiness of America."
Washington was, in fact, utterly without religious prejudice.
When he visited Newport, Rhode Island, in August 1790, he
had a friendly exchange with the Jewish community there in
which he declared that Government of the United States
"gives to bigotry no sanction" and "to persecution no assis-
tance. "
221
BIBLE QUOTE "It is impossible to rightly govern the world
without God and the Bible."
Washington was baptized in the Anglican (later Episcopal)
church, served as a vestryman, attended church fairly regu-
larly, and believed that religion was the foundation for
morality, but he rarely mentioned the Bible in his letters and
public addresses, and never said, publicly or privately, that
11
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
George Washington 127
it was "impossible to rightly govern the world without God
and the Bible." In notes which he jotted down in preparation
for one of his speeches, he did say something about the Bible
and human depravity. "The blessed Religion revealed in the
word of God," he wrote, "will remain an eternal and awful
monument to prove that the best Institutions may be abused
by human depravity; and that they may even, in some in-
stances be made subservient to the vilest of purposes." In the
end, however, for whatever reasons, he decided not to make
use of this statement, which is the only serious reference he
ever made to the Bible.
222
CAN'T-TELL-A-LIE QUOTE "I cannot tell a lie."
The assertion that when the Father of Our Country was a
little boy he told his dad he couldn't tell a lie is itself a pre-
varication. It's an innocent one all the same. It was put into
circulation by an Anglican minister, Mason Locke ("Parson")
Weems, a writer with a bent for hagiography, who wrote a
biography of Washington shortly after the latter's death in
1799. When George was about six years old, Weems tells us,
his father gave him a hatchet, and the boy at once hacked up
a handsome young cherry tree belonging to the family.
"George," said the father sternly, confronting the boy, "do
you know who killed that beautiful little cherry tree yonder
in the garden?" This, says Weems, was "a tough question)
and George staggered under it for a moment." Recovering
himself, though, he bravely cried out: "I can't tell a lie, Pa;
you know I can't tell a lie. I did cut it with my hatchet."
The Great Confrontation Scene ends with a Great Em-
brace. "Run to my arms, you dearest boy," cries Washing-
ton's father, in transports, "run to my arms; glad am I,
George that you killed my tree, for you have paid me for it
a thousand fold. Such an act of heroism in my son, is worth
more than a thousand trees, though blossomed with silver,
and their fruits of purest gold."22B
12
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
128 They Never Said It
DEFICIT-SPENDING QUOTE "Continued deficit spending must
ultimately endanger all governments."
The Father of His Country would probably have been stupe-
fied by the way the national debt skyrocketed during Ronald
Reagan's eight years in the White House, but he never said
anything in his own day about "deficit spending." The term,
deficit spending, is strictly 20th-century, and not even Alex-
ander Hamilton, Washington's Secretary of the Treasury,
used it. But Hamilton did devise a plan by which the new
Federal Government took over both the national and state
debts left over from the American Revolution. And Wash-
ington approved the plan.
224
DIE-HARD QUOTE "Doctor, I die hard, but I am not afraid to
go. Bring me the Book.''
Shortly before he died at Mount Vernon on December 13,
1799, Washington is supposed to have asked for a Bible. But
neither his doctors nor Tobias Lear, his private secretary,
recorded any such request, and they were all with him at the
end and wrote up his last moments afterwards. Washington
did tell Dr. James Craik, "Doctor, I die hard, but I am not
afraid to go," but he went on, not to request a Bible, but to
add, "My breath cannot last long." But these were not his
last words. Although he had difficulty speaking toward the
end, he did manage to ask what time it was, urge the doctors
to "let me go off quietly," and express some concern lest he
be buried alive. "I am just going," he finally told Lear.
"Have me decently buried, and do not let my body be put
into the vault in less than three days after I am dead." Lear
nodded dolefully. "Do you understand?" Washington asked
in a faint voice. "Yes, sir," said Lear. "'Tis well," breathed
Washington. These were his last words.
225
LORD-GOD-OF-GODS QUOTE "The Lord God of gods, the Lord
God of gods, He knoweth, and Israel He shall know; if it be
r
t
c
l
}
~
13
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
d It
lUSt
Ipe-
tald
said
TID,
.lex-
ury,
new
.tate
ash-
d to
13,
But
:ary,
: the
ston
not
1t to
: his
the
:tors
;the
... ear.
put
Lear
sked
thed
Lord
it be
George Washington 129
rebellion, or if in transgression against the Lord (save us not
this day)."
A little girl is supposed to have heard Washington utter this
prayer on the eve of battle during the American Revolution,
and Woodrow Wilson included it in his biography of Wash-
ington in 1896. But there is no evidence for Washington's
ever having uttered such a prayer, and it is entirely out of
character. Washington was a Deist, not an orthodox Chris-
tian, and though he belonged to the Episcopal Church and
regarded religion as an important civilizing force in society,
he simply was not given to outbursts of evangelical fervor.
226
NOT-A-CHRISTIAN-COUNTRY QUOTE "The Government of the
United States is not in any sense founded on the Christian
religion."
Freethinkers have made much of this supposed statement by
Washington when he was President. But the statement was
not Washington's; it was Joel Barlow's, and it appeared in
the Treaty of Peace and Friendship which Barlow, American
consul in Algiers, concluded with Tripoli on November 4,
1796. Eager to make it clear that Christianity was not an
American state religion, and that therefore the U.S. govern-
ment bore no official hostility toward Islam, Barlow included
a clause in the treaty stating: "As the Government of the
United States of America is not in any sense founded on the
Christian religion; as it has in itself no character of enmity
against the laws, religion, or tranquility of Musselmen; and
as the said States never have entered into any war or act of
hostility against any Mehomitan nation, it is declared by the
parties, that no pretext arising from religious opinions shall
ever produce an interruption of the harmony existing be-
tween the two countries."
227
14
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
THE RECORDS
OF THE
FEPERAL CONVENTION
EDITED BY
l\1AX FARRAND
'P.OFESSO:R OJ' RISTOJ.Y J:N 'YALE UNIVEUrn
VoLUI.1E I
.
.. .
. . .
. .
......
NEW HAVEN': YALE UNJV.EltSITY PRESS
LONDON: HENRY FROWDE.
OXFORD UNIVEB.SITY PR.ESS
MCMXl
, JJ
.. ,_ """' .. ~ .. ........ "' - ..._
15
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
450 .RECORDS OF 1.HE FEDERAL CONVENTION
---------- ---- ----
Thursda-y l\.1A.DISON . ]uftt
------------- -----------------
for equa.lity of votes among the St.a.t.es is that the States .as
such bein.g equal, and being represented not as districts
jndividuah, but in their political & corporate capacities; ate
entitled to an equality of .1\ccording to this mode of
reasoning the representation of the in Engld which
has been allowed on all hands to be the rotten part of the Con-
stitution, is perfectly- right & pi'opel'. arc like-the States
represented in thP.ir corporate capacity Hke the there-
fore they are entitled to equal voices, old Sarum to as many
as London. And instead of the injury supposed hitl1erto to
be done to London, the true groond of complaint lies with old
Sru-un1; for London instead of t;wo is. her share,
sends four representati\'CS to Parliament.
l\1r. Sherman. The question is not what rights . natuz:aily
belong to men; but how they ma_y he t'I)C)st equally & effec-
tually tn guanlcd in Society. And if some give up
others in order to obtain this end, there can be {no} room. for
cotnp1aint. To do otherwise, to require a.n equal con.c.ession .
from all, if it would create danger to the rights of some, would.
be sacrificing the end to the means. The rich man \vho
enters into Society along with the poor givt?S up more
than the poor man. yet with a.n equal vote he is equally
\Verc he to have more votes than the poor man in proportion.
to his superior stake, t he righ {")f the poor man would immedi.:.
ateiy cease to be secure. This OOllsideration preva-iied when : -
the of confederation were for1ned. . , ,; .. -' .
(fhe determination of the question from -striking out the .
word "not"' was put oft' tiU to morrow at the req.ue5t' of the
Deputies of N. _York.}
12
. . . .. , .
[Dr. . . . .
.. .
Mr. President
The small progress we have n1ade after. 4 or weeks. dose.
co out .. best". 2 taken from jo.ul.;iill.
"'Madison originally m.1de an dbstract of speet:b in.about worda.
J"hjs 'MUi later OUt -;- ilt'l.d this made: "tee Oppoatt.e ... & lhe.
oi Doctr Fin this place.b On the oppoaitc page ht:.tding. zS,
in convention,.. i(\ the which is i gh'cn- but without iiame. .
Among the Papers in the of Cong:n:ss is a .ct,py of. . .. .
hardly at all from the text except in more frequent -use Of . . . "' . . .
16
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
RECORDS OF THJ.: Ji'J:DERAL . 451
sda-y
... ., .....
1dance &: continual J'easonings \.vith .. each other--.: our
rent sentiments on almost eve.ry question:f several of
producing as many noes as ays, is methinks a melancho1y
f of the in1perlection of the Human Understanding. We
seem to feel
13
our own \Vant of political wis9oJn, since
Lave been running about in search of it. \Ve have gone
to ancient history for models of Government, and exam-.
the different forms of those Republics l'tthich having been
ed \Vith the seeds of their own dissolution now no longer
..t\nd we ha'\."e Jvl,)dern all round
find none of their Constitutions suitable to our circum-
..
n this situation of this groping as it were in
lark to find truth, aud scarce able to distinguish
1cn presented to us, hov1t has it happened, Sir, that we
not hltherto once thought of humbly applying to the
er of lights to illuminate out under& tan dings ( -In the
1ning of the Contest \\rith G. Britain, when l\'C
ble of danger wt had daily prayer iu ll1is room for
Le protection.--Our prayers, Sir, were .. a.nd .they
graciously answered. All of us who in.
1truggle must have observf.d frequent instances of a .
Ltending providence in our favor. To that kind: : . :.
e we 0\\'e thi3 happy opportunity of consulting in. peace . : . . .
1e means of establishing our future national felicity... :And
we no\v forgotten that po"'rerlul frien4! .or do we:imag;n.e
we no ]ol)ger need his assistance? I have Sir, a:
time, and the longer I live, the more convinci.ng . .
: of this trn th -- that God l
4
.. in tkt . a.lf of men.
if a sparrow cannot fall to the ground :without his noticet
:>robable that an empire can rise \vitl:tout his ajd? \\le .ha\.e
. assured, Sir, in the sacred writings, th-at " e:xcept the
build the House they labour in vain that build it." I .
y belit:ve this; and I also believe that his cOn-
ng aid we shall succeed in this political building 110 better
the Builders of Ra.bel: We shall be di':'ided by .our little
J.1 "!oc.-:P' is in Frnnldin 1\>fS.
M "God'' mice in Fr-.anHio :\fS.
17
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
452 RECORDS OF THE FEDERAL CONVENTION
Junt il$
partial local interests; our projects will be confounded, we
ourselves shaU become a reproach and bye word down to future
ages. And \\'hat is worse., mankind may hereafter from thi
unfortunat in$tanc , de pair of csub ishing Gov rnments by
tluman Wisdom and leave it to chance, war and conqu st.
I erefore b g leave to tnove - that h nc forth prayen
imploring the ssistance of Heaven, and its blessing on our
deliberations, be held in this Assembly every morning b fore
we proceed to business, and that one or more of the Cl rgy
of this City be requested to officiate in that service---
Mr .. Shannan seconded the motion.
Mr. Hamilton &. s veral others expressed their ap.pr heo-
sions that how'ever proper suc'h a resolution might have been
at the beginning of the convention, it might at this late day,
1. bring on it om disagre able animadversions. & 2. lead the
public to belie that the embarrassment.') and dissentions
within the convention, had suggested this measure. It was
answered by Doer. F. Mr. Sh n:nan & others, that the past
omission of a duty couJ.d not justify a further omission- that
the rejection of $UCh a proposition \vould pose the Con ..
vcntion to more unpleasant ani.r adve than the adoptlon
of it.: and t.ha the alarm out of doors that might be cite-d
.fror the state of things within. would at t e as likely to
do good as ill.
fr. Williamson) observed that the true cause of th omi.s-
aion could not be mistak n. The Conv ntion had no fu.nds ..
r. Randolph propos d in order to giv a favorable aspect
to ye. measure, th t sermon be preached at tbe tequest of the
convention on 4th of July, d1e anniversary .of Independence,-
& thenc forward prayer be used in ye Convention every
morning. Dr. Frankn. zded. this motion After several unsuc-
c sful atten1pts for sil ntly postponing the matter by adjourng.
the adjournment was at l ngtb carried, without any vote. on
the motion. u
11
la tbe Ft lin the uou is dded:- 'ne Convention, UO(:f't
three or four pene>ns., thought P yen UDneceu ry.' A distorted account of this
incidtJiat i$ t iven in Appctnd.U: A, CCCLV; t a CXCV
1
CCCLXVII, CCCI..uXXTX
and CCCXCIJL
18
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
e s'
nst
Edited by
Philip B Kurland
and
Ralph Lerner
VOLUME ONE
Major Themes
s ~
Liberty Fund
Indianapolis
tio
19
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 10, SEPARATION OF POWERS, NO. 5
possible to keep the Legislative and Executive Parts asun-
der, that they may be a check upon one another. Our Gov-
ernment trusts the King with no part of the Legislative but
a Negative Voice, which is absolutely necessary to preserve
the Executive. One part of the Duty of the House of Com-
mons is to punish Offenders, and redress the Grievances
occasion'd by the Executive Part of the Government; and
how can that be done if they should happen to be the same
Persons, unless they would be publick-spirited enough to
hang or drown themselves?
But in my Opinion, in another thing of no less Impor-
tance, we deviated in Charles the Second's time from our
Constitution: for tho we were in a Capacity of punishing
Offenders, yet we did not know legally who they were.
The Law has been always very tender of the Person of the
King, and therefore has dispos'd the Executive Part of the
Government in such proper Channels, that whatsoever
lesser Excesses are committed, they are not imputed to
him, but his Ministers are accountable for them: his great
Seal is kept by his Chancellor, his Revenue by his Trea-
surer, his Laws are executed by his Judges, his Fleet is
manag'd by his Lord High Admiral, who are all accounta-
ble for their Misbehaviour. Formerly all Matters of State
and Discretion was debated and resolv'd in the Privy
Council, where every Man subscrib'd his Opinion, and was
answerable for it. The late King Charles was the first who
broke this most excellent part of our Constitution, by set-
tling a Cabal or Cabinet Council, where all Matters of Con-
sequence were debated and resolv'd, and then brought to
the Privy Council to be confirm'd. The first footsteps we
have of this Council in any European Government were in
Charles the Ninth's time of France, when resolving to mas-
sacre the Protestants, he durst not trust his Council with
it, but chose a few Men who he call'd his Cabinet Council:
and considering what a Genealogy it had, 'tis no wonder it
has been so fatal both to King and People. To the King:
for whereas our Constitution has provided Ministers in the
several parts of the Government to answer for Miscar-
riages, and to skreen him from the hatred of the People;
this on the contrary protects the Ministers, and exposes
the King to all the Complaints of his Subjects. And 'tis as
dangerous to the People: for whatever Miscarriages there
are, no body can be punish'd for them; for they justify
themselves by a Sign Manual, or perhaps a private Direc-
tion from the King: and then we have run it so far, that
we can't follow it. The Consequence of this must be con-
tinual Heartburnings between King and People: and no
one can see the Event.
5
MoNTESQUIEU, SPIRIT oF LAws,
BK. 11, CHS. 6-7
1748
(See ch. 17, no. 9)
318
6
WILLIAM BLACKSTONE, CoMMENTARIES
1: 149-51' 259-60
1765
It is highly necessary for preserving the ballance of the
constitution, that the executive power should be a branch,
though not the whole, of the legislature. The total union
of them, we have seen, would be productive of tyranny;
the total disjunction of them for the present, would in the
end produce the same effects, by causing that union,
against which it seems to provide. The legislature would
soon become tyrannical, by making continual encroach-
ments, and gradually assuming to itself the rights of the
executive power. Thus the long parliament of Charles the
first, while it acted in a constitutional manner, with the
royal concurrence, redressed many heavy grievances and
established many salutary laws. But when the two houses
assumed the power of legislation, in exclusion of the royal
authority, they soon after assumed likewise the reins of
administration; and, in consequence of these united pow-
ers, overturned both church and state, and established a
worse oppression than any they pretended to remedy. To
hinder therefore any such encroachments, the king is him-
self a part of the parliament: and, as this is the reason of
his being so, very properly therefore the share of legisla-
tion, which the constitution has placed in the crown, con-
sists in the power of rejecting, rather than resolving; this
being sufficient to answer the end proposed. For we may
apply to the royal negative, in this instance, what Cicero
observes of the negative of the Roman tribunes, that the
crown has not any power of doing wrong, but merely of
preventing wrong from being done. The crown cannot be-
gin of itself any alterations in the present established law;
but it may approve or disapprove of the alterations sug-
gested and consented to by the two houses. The legislative
therefore cannot abridge the executive power of any rights
which it now has by law, without it's own consent; sim:e
the law must perpetually stand as it now does, unless all
the powers will agree to alter it. And herein indeed con-
sists the true excellence of the English government, that
all the parts of it form a mutual check upon each other.
In the legislature, the people are a check upon the nobil-
ity, and the nobility a check upon the people; by the mu-
tual privilege of rejecting what the other has resolved:
while the king is a check upon both, which preserves th
executive power from encroachments. And this very ex-
ecutive power is again checked, and kept within du
bounds by the two houses through the privilege they hav
of enquiring into, impeaching, and punishing the cond.u t
(not indeed of the king, which would destroy his constitu-
tional independence; but, which is more beneficial to th .
public) of his evil and pernicious counsellors. Thus eve
branch of our civil polity supports and is supported, r
ulates and is regulated, by the rest; for the two houses ~ -
20
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 10, SHAilATION OF IPOWE!ltS, NO. 9
. two directions of opposite interest, and
t.HIh
1
: another still different from them both,
l
Jr rogauve d. h .
l l r Jl keep each other from excee mg t e1r
h
t , mutua Y . d f
t
1
. . . while the whole ts prevente rom separa-
tm1tS, d
d dicially connected together by the mrxe na-
n afl ar
1
f h l 1 d
uo of the crown, which is a o t e. auve,
wr t utive magistrate. Ltke three d1stmct powers m
th o e exec . . .
they Jomtly tmpel the machme of government
antes, . . .
d
. t
1

0
n different from what etther, actmg by them-
lrec . . .
ould have done; but at the same tlme m a dlrec-
1 'w . .
. taking of each, and formed out of all; a dtrecuon
uon par . . .
wm li1 constitutes the true lme of the hberty and happmess
of tdile community.
] lil this distinct and separate existen.ce of judicial
er in a peculiar body of men, nommated mdeed, but
p0W ' .
t removeable at pleasure, by the crown, conststs one
::m.lil preservative of the public cannot sub-
'st long in any state, unless the admtmstrauon of
jl!l.stice be in some degree separated both from the legtsla-
ui w.e and also from the executive power. Were it joined
with the legislative, the life, liberty, and property, of the
subject would be in the hands of arbitrary judges, whose
decisions would be then regulated only by their own opin-
i9ns, and not by any fundamental principles of law; which,
though legislators may depart from, yet judges are bound
to observe. Were it joined with the executive, this union
might soon be an over ballance for the legislative. For
which reason, by the statute of 16 Car. I. c. 10. which abol-
ished the court of star chamber. effectual care is taken to
remove all judicial power out of the hands of the king's
privy council; who, as then was evident from recent in-
stances, might soon be inclined to pronounce that for law,
which was most agreeable to the prince or his officers.
Nothing therefore is more to be avoided, in a free consti-
tution, than uniting the provinces of a judge and a minis-
ter of state. And indeed, that the absolute power, claimed
and exercised in a neighbouring nation, is more tolerable
than that of the eastern empires, is in great measure owing
to their having vested the judicial power in their parlia-
ments, a body separate and distinct from both the legisla-
tive and executive: and, if ever that nation recovers it's
former liberty, it will owe it to the efforts of those assem-
blies. In Turkey, where every thing is centered in the sul-
tan or his ministers, despotic power is in it's meridian, and
wears a more dreadful aspect.
7
JOHN ADAMS, THOUGHTS oN GovERNMENT
Apr. 1776
Papers 4:88-90
(See ch. 4, no. 5)
8
[NSTIRUCTA:ONS OIF THE lNHA!BITANTS OIF THE TOWN
o F BosTON To THEIR R EPRESENTATIVES
I N CoNGlllJEss
1776
133
It is essential to liberty, that the legislative, judicial, and
executive powers of government be, as nearly as possible,
independent of, and separate from each other; for where
they are united in the same persons, or number of per-
sons, there would be wanting that mutual check which is
the principal security against the making of arbitrary laws,
and a wanton exercise of power in the execution of them.
It is also of the highest importance, that every person in a
judiciary department employ the greatest part of his time
and attention in the duties of his office; we therefore fur-
ther"instruct you, to procure the enacting such law or laws,
as shall make it incompatible for the same person to hold
a seat in the legislative and executive departments of gov-
ernment, at one and the same time: that shall render the
judges, in every judicatory through the colony, dependent,
not on the uncertain tenure of caprice or pleasure, but on
an unimpeachable deportment in the important duties of
their station, for their continuance in office: and to pre-
vent the multiplicity of offices in the same person, that
such salaries be settled upon them as will place them above
the necessity of stooping to any indirect or collateral
means for subsistence. We wish to avoid a profusion of the
public moneys on the one hand, and the danger of sacri-
ficing our liberties to a spirit of parsimony on the other.
9
THOMAS jEFFERSON, NOTES ON THE STATE OF
VIRGINIA, QUERY 13, 120-21
1784
4. All the powers of government, legislative, executive,
and judiciary, result to the legislative body [in the Virginia
Constitution of 1776]. The concentrating these in the same
hands is precisely the definition of despotic government.
It will be no alleviation that these powers will be exercised
by a plurality of hands, and not by a single one. 173 des-
pots would surely be as oppressive as one. Let those who
doubt it turn their eyes on the republic of Venice. As little
will it avail us that they are chosen by ourselves. An elective
despotism was not the government we fought for; but one
which should not only be founded on free principles, but
in which the powers of government should be so divided
and balanced among several bodies of magistracy, as that
no one could transcend their legal limits, without being
319
21
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 10, SEPARATION OF POWERS, NO. 10
effectually checked and restrained by the others. For this
reason that convention, which passed the ordinance of
government, laid its foundation on this basis, that the leg-
islative, executive and judiciary department should be sep-
arate and distinct, so that no person should exercise the
powers of more than one of them at the same time. But
no barrier was provided between these several powers.
The judiciary and executive members were left dependant
on the legislative, for their subsistence in office, and some
of them for their continuance in it. If therefore the legis-
lature assumes executive and judiciary powers, no opposi-
tion is likely to be made; nor, if made, can it be effectual;
because in that case they may put their proceedings into
the form of an act _ of assembly, which will render them
obligatory on the other branches. They have accordingly,
in many instances, decided rights which should have been
left to judiciary controversy: and the direction of the ex-
ecutive, during the whole time of their session, is becom-
ing habitual and familiar. And this is done with no ill in-
tention. The views of the present members are perfectly
upright. When they are led out of their regular province,
it is by art in others, and inadvertence in themselves. And
this will probably be the case for some time to come. But
it will not be a very long time. Mankind soon learn to make
interested uses of every right and power which they pos-
sess, or may assume. The public money and public liberty,
intended to have been deposited with three branches of
magistracy, but found inadvertently to be in the hands of
one only, will soon be discovered to be sources of wealth
and dominion to those who hold them; distinguished too
by this tempting circumstance, that they are the instru-
ment, as well as the object of acquisition. With money we
will get men, said Caesar, and with men we will get money.
Nor should our assembly be deluded by the integrity of
their own purposes, and conclude that these unlimited
powers will never be abused, because themselves are not
disposed to abuse them. They should look forward to a
time, and that not a distant one, when corruption in this,
as in the country from which we derive our origin, will
have seized the heads of government, and be spread by
them through the body of the people; when they will pur-
chase the voices of the people, and make them pay the
price. Human nature is the same on every side of the At-
lantic, and will be alike influenced by the same causes. The
time to guard against corruption and tyranny, is before
they shall have gotten hold on us. It is better to keep the
wolf out of the fold, than to trust to drawing his teeth and
talons after he shall have entered.
10
RECORDS OF THE FEDERAL CoNvENTION
[1 :86; Madison, 2 june]
Mr. Dickenson considered the business as so important
that no man ought to be silent or reserved. He went into
a discourse of some length, the sum of which was, that the
320
Legislative, Executive, & Judiciary departments ought to
be made as independt. as possible; but that such an Exec-
utive as some seemed to have in contemplation was not
consistant with a republic; that a firm Executive could only
exist in a limited monarchy. In the British Govt. itself the
weight of the Executive arises from the attachments which
the Crown draws to itself, & not merely from the force of
its prerogatives. In place of these attachments we must
look out for something else. One source of stability is the
double branch of the Legislature. The division of the
Country into distinct States formed the other principal
source of stability. This division ought therefore to be
maintained, and considerable powers to be left with the
States. This was the ground of his consolation for the fu-
ture fate of his Country. Without this, and in case of a
consolidation of the States into one great Republic we
might read its fate in the history of smaller ones. A limited
Monarchy he considered as one of the best Governments
in the world. It was not certain that the same blessings were
derivable from any other form. It was certain that equal
blessings had never yet been derived from any of the re-
publican form. A limited monarchy however was out of
the question. The spirit of the times-the state of our af-
fairs, forbade the experiment, if it were desireable. Was it
possible moreover in the nature of things to introduce it
even if these obstacles were less insuperable. A House of
Nobles was essential to such a Govt. Could these be created
by a breath, or by a stroke of the pen? No. They were the
growth of ages, and could only arise under a complication
of circumstances none of which existed in this Country.
But though a form the most perfect perhaps in itself be
unattainable, we must not despair. If antient republics
have been found to flourish for a moment only & then
vanish forever, it only proves that they were badly consti-
tuted; and that we ought to seek for every remedy for
their diseases. One of these remedies he conceived to be
the accidental lucky division of this country into distinct
States; a division which some seemed desirous to abolish
altogether.
[1 :97; Madison, 4 June]
First Clause of Proposition 8th relating to a Council of
Revision taken into consideration.
Mr. Gerry doubts whether the Judiciary ought to form
a part of it, as they will have a sufficient check agst. en-
croachments on their own department by their exposition
of the laws, which involved a power of deciding on their
Constitutionality. In some States the Judges had actually
set aside laws as being agst. the Constitution. This was
done too with general approbation. It was quite foreign
from the nature of ye. office to make them judges of the
policy of public measures. He moves to postpone the
clause in order to propose "that the National Executive
shall have a right to negative any Legislative act which
shall not be afterwards passed by parts of each
branch of the national Legislature."
Mr. King seconds the motion, observing that the Judges
ought to be able to expound the law as it should come
before them, free from the bias of having participated in
its formation.
22
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 10, SEPARATION OF POWERS, NO. 14
beyond controversy; in the bills of rights or constitutions
of New-Hampshire, Massachusetts, Maryland, Virginia,
North-Carolina and Georgia, it is expressly declared. "That
the legislative, executive and judicial departments, shall be for-
ever separate and distinct from each other." In Pennsylvania and
Delaware, they are effectually separated without any par-
ticular declaration of the principle. In the other states in-
deed, the executive branch possesses more or less of the
executive [legislative?] power-And here it must appear
singular that the state of Massachusetts, where the doc-
trine of a separate jurisdiction is most positively estab-
lished, and in whose bill of rights these remarkable words
are to be found: "The executive shall never exercise the
legislative and judicial powers, or either of them, to the
end it may be a government of laws and not of men." (30)
Yet in that commonwealth and New-Hampshire, the ex-
ecutive branch, which consists of a single magistrate, has
more controul over the legislature than in any other state;
for there, if the governor refuses his assent to a bill, it
cannot be passed into a law, unless two-thirds of the house
afterwards concur. In New-York the same power is given
to a Council of Revision, consisting of the Governor, the
Chancellor and Judges of the Supreme Court, or any
three of them, of which the Governor is to be one. In
Rhode-Island and Connecticut, whose governments were
established before the revolution, the Governor has a sin-
gle vote as a member of the upper house, and New-Jersey
has adopted this part of their constitution. In Georgia the
laws are to be revised by the Governor and Council, but
they can do no more than give their opinion upon them.
In Maryland the bills are to be signed by the governor
before they can be enacted, and in South-Carolina they are
to be sealed with the great seal, which is in the governor's
custody. But in the first of these states, the constitution
prescribes, that the governor shall sign the bills, and in the
latter, a joint committee of both houses of legislature is to
wait upon chief magistrate to receive and return the great
seal, which implies that he is bound to deliver it to them,
for the special purpose of affixing it to the laws of the
state. Pennsylvania has proceeded upon a much more ra-
tional ground, their legislature having a particular seal of
their own, and their laws requiring only to be signed by
the speaker. If in Maryland or South-Carolina a difference
should ever arise between the legislature and the gover-
nor, and the latter should refuse to sign the laws, or to
deliver the great seal, the most fatal consequences might
ensue.
Here then we see the great leading principle of the ab-
solute division of the legislative from the executive jurisdiction,
admitted in almost every one of the American states as a
fundamental maxim in the politics of a free country. The
theory of this general doctrine is every where established,
though a few states have somewhat swerved from it in the
practice. From whence we must conclude, that even the
knowledge and full conviction of a new political truth will
not always immediately conquer inveterate habits and
prejudices. The idea of the negative, which the constitu-
tion of England gives to the monarch over the proceedings
of the other branches of parliament, although it has so
325
long become obsolete, has had an effect upon timid minds,
and upon the minds of those who could not distinguish
between the form and spirit of the British constitution. They
would not grant to the executive branch an absolute neg-
ative over the legislature, but yet they tried every method
to introduce something similar to it. They reprobated the
doctrine in the most express words, and yet they could not
bear to part entirely with it. It is curious to observe how
many different ways they have endeavored to conciliate
truth with prejudice. Of those states who have allowed the
executive branch to intermeddle with the proceedings of
the legislature, no two (New-Hampshire and Massachu-
setts excepted) have done it exactly in the same manner.
They have tried every possible medium, but having lost
sight of the original principle which they had already es-
tablished, and which alone could have been their safest
guide, they groped about in the dark, and could not find
any solid ground on which to establish a general rule. Like
Noah's dove, being once out of the ark of truth, they could
not find elsewhere a place to rest their feet.
13
jAMES MADISON, fEDERALIST, NO. 37, 233-34
11 Jan. 1788
(See ch. 9, no. 9)
14
jAMES MADISON, FEDERALIST, NO. 47, 323-31
30 Jan. 1788
One of the principal objections inculcated by the more re-
spectable adversaries to the constitution, is its supposed vi-
olation of the political maxim, that the legislative, execu-
tive and judiciary departments ought to be separate and
distinct. In the structure of the federal government, no
regard, it is said, seems to have been paid to this essential
precaution in favor of liberty. The several departments of
power are distributed and blended in such a manner, as at
once to destroy all symmetry and beauty of form; and to
expose some of the essential parts of the edifice to the
danger of being crushed by the disproportionate weight of
other parts.
No political truth is certainly of greater intrinsic value
or is stamped with the authority of more enlightened pa-
trons of liberty than that on which the objection is
founded. The accumulation of all powers legislative, ex-
ecutive and judiciary in the same hands, whether of one, a
few or many, and whether hereditary, self appointed, or
elective, may justly be pronounced the very definition of
tyranny. Were the federal constitution therefore really
chargeable with this accumulation of power or with a mix-
23
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 10, SEPARATION OF POWERS, NO. 14
ture of powers having a dangerous tendency to such an
accumulation, no further arguments would be necessary to
inspire a universal reprobation of the system. I persuade
myself however, that it will be made apparent to every
one, that the charge cannot be supported, and that the
maxim on which it relies, has been totally misconceived
and misapplied. In order to form correct ideas on this im-
portant subject, it will be proper to investigate the sense,
in which the preservation of liberty requires, that the three
great departments of power should be separate and dis-
tinct.
The oracle who is always consulted and cited on this
subject, is the celebrated Montesquieu. lf he be not the
author of this invaluable precept in the science of politics,
he has the merit at least of displaying, and recommending
it most effectually to the attention of mankind. Let us en-
deavour in the first place to ascertain his meaning on this
point.
The British constitution was to Montesquieu, what Ho-
mer has been to the didactic writers on epic poetry. As the
latter have considered the work of the immortal Bard, as
the perfect model from which the principles and rules of
the epic art were to be drawn, and by which all similar
works were to be judged; so this great political critic ap-
pears to have viewed the constitution of England, as the
standard, or to use his own expression, as the mirrour of
political liberty; and to have delivered in the form of ele-
mentary truths, the several characteristic principles of that
particular system. That we may be sure then not to mis-
take his meaning in this case, let us recur to the source
from which the maxim was drawn.
On the slightest view of the British constitution we must
perceive, that the legislative, executive and judiciary de-
partments are by no means totally separate and distinct
from each other. The executive magistrate forms an inte-
gral part of the legislative authority. He alone has the pre-
rogative of making treaties with foreign sovereigns, which
when made have, under certain limitations, the force of
legislative acts. All the members of the judiciary depart-
ment are appointed by him; can be removed by him on
the address of the two Houses of Parliament, and form,
when he pleases to consult them, one of his constitutional
councils. One branch of the legislative department forms
also, a great constitutional council to the executive chief;
as on another hand, it is the sole depositary of judicial
power in cases of impeachment, and is invested with the
supreme appellate jurisdiction, in all other cases. The
judges again are so far connected with the legislative de-
partment, as often to attend and participate in its deliber-
ations, though not admitted to a legislative vote.
From these facts by which Montesquieu was guided it
may clearly be inferred, that in saying "there can be no
liberty where the legislative and executive powers are
united in the same person, or body of magistrates," or "if
the power of judging be not separated from the legislative
and executive powers," he did not mean that these depart-
ments ought to have no partial agency in, or no controul
over the acts of each other. His meaning, as his own words
import, and still more conclusively as illustrated by the ex-
ample in his eye, can amount to no more than this, that
326
where the whole power of one department is exercised by
the same hands which possess the whole power of another
department, the fundamental principles of a free consti-
tution, are subverted. This would have been the case in the
constitution examined by him, if the King who is the sole
executive magistrate, had possessed also the compleat leg-
islative power, or the supreme administration of justice; or
if the entire legislative body, had possessed the supreme
judiciary, or the supreme executive authority. This how-
ever is not among the vices of that constitution. The mag-
istrate in whom the whole executive power resides cannot
of himself make a law, though he can put a negative on
every law, nor administer justice in person, though he has
the appointment of those who do administer it. The
judges can exercise no executive prerogative, though they
are shoots from the executive stock, nor any legislative
function, though they may be advised with by the legisla-
tive councils. The entire legislature, can perform no judi-
ciary act, though by the joint act of two of its branches, the
judges may be removed from their offices; and though
one of its branches is possessed of the judicial power in
the last resort. The entire legislature again can exercise no
executive prerogative, though one of its branches consti-
tutes the supreme executive magistracy; and another, on
the empeachment of a third, can try and condemn all the
subordinate officers in the executive department.
The reasons on which Montesquieu grounds his maxim
are a further demonstration of his meaning. "When the
legislative and executive powers are united in the same
person or body" says he, "there can be no liberty, because
apprehensions may arise lest the same monarch or senate
should enact tyrannical laws, to execute them in a tyrannical
manner." Again "Were the power of judging joined with
the legislative, the life and liberty of the subject would be
exposed to arbitrary controul, for the judge would then be
the legislator. Were it joined to the executive power, the
judge might behave with all the violence of an oppressor."
Some of these reasons are more fully explained in other
passages; but briefly stated as they are here, they suffi-
ciently establish the meaning which we have put on this
celebrated maxim of this celebrated author.
If we look into the constitutions of the several states we
find that notwithstanding the emphatical, and in some in-
stances, the unqualified terms in which this axiom has
been laid down, there is not a single instance in which the
several departments of power have been kept absolutely
separate and distinct. New-Hampshire, whose constitution
was the last formed, seems to have been fully aware of the
impossibility and inexpediency of avoiding any mixture
whatever of these departments; and has qualified the doc-
trine by declaring "that the legislative, executive and judi-
ciary powers ought to be kept as separate from, and inde-
pendent of each other as the nature of a free government will
admit; or as is consistent with that chain of connection, that binds
the whole fabric of the constitution in one indissoluble bond of
unity and amity." Her constitution accordingly mixes these
departments in several respects. The senate which is a
branch of the legislative department is also a judicial tri-
bunal for the trial of empeachments. The president who is
the head of the executive department, is the presiding
24
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 10, SEPARATION OF POWERS, NO. 14
member also of the senate; and besides an equal vote in all
cases, has a casting vote in case of a tie. The executive
head is himself eventually elective every year by the legis-
lative department; and his council is every year chosen by
and from the members of the same department. Several
of the officers of state are also appointed by the legisla-
ture. And the members of the judiciary department are
appointed by the executive department.
The constitution of Massachusetts has observed a suffi-
cient though less pointed caution in expressing this fun-
damental article of liberty. It declares "that the legislative
department shall never exercise the executive and judicial
powers, or either of them: The executive shall never ex-
ercise the legislative and judicial powers, or either of them:
The judicial shall never exercise the legislative and execu-
tive powers, or either of them." This declaration corre-
sponds precisely with the doctrine of Montesquieu as it has
been explained, and is not in a single point violated by the
plan of the Convention. It goes no farther than to prohibit
any one of the entire departments from exercising the
powers of another department. In the very constitution to
which it is prefixed, a partial mixture of powers has been
admitted. The Executive Magistrate has a qualified nega-
tive on the Legislative body; and the Senate, which is a
part of the Legislature, is a court of impeachment for
members both of the executive and judiciary departments.
The members of the judiciary department again are ap-
pointable by the executive department, and removeable by
the same authority, on the address of the two legislative
branches. Lastly, a number of the officers of government
are annually appointed by the legislative department. As
the appointment to offices, particularly executive offices, is
in its nature an executive function, the compilers of the
Constitution have in this last point at least, violated the
rule established by themselves.
I pass over the constitutions of Rhode-Island and Con-
necticut, because they were formed prior to the revolu-
tion; and even before the principle under examination
had become an object of political attention.
The constitution of New-York contains no declaration
on this subject; but appears very clearly to have been
framed with an eye to the danger of improperly blending
the different departments. It gives nevertheless to the ex-
ecutive magistrate a partial controul over the legislative
department; and what is more, gives a like controul to the
judiciary department, and even blends the executive and
judiciary departments in the exercise of this controul. In
its council of appointment, members of the legislative are
associated with the executive authority in the appointment
of officers both executive and judiciary. And its court for
the trial of impeachments and correction of errors, is to
consist of one branch of the legislature and the principal
members of the judiciary department.
The constitution of New-Jersey has blended the differ-
ent powers of government more than any of the preced-
ing. The governor, who is the executive magistrate, is ap-
pointed by the legislature; is chancellor and ordinary or
surrogate of the state; is a member of the supreme court
of appeals, and president with a casting vote, of one of the
legislative branches. The same legislative branch acts again
as executive council to the governor, and with him consti-
tutes the court of appeals. The members of the judiciary
department are appointed by the legislative department,
and removeable by one branch of it, on the impeachment
of the other.
According to the constitution of Pennsylvania, the pres-
ident, who is head of the executive department, is annually
elected by a vote in which the legislative department pre-
dominates. In conjunction with an executive council, he
appoints the members of the judiciary department, and
forms a court of impeachments for trial of all officers, ju-
diciary as well as executive. The judges of the supreme
court, and justices of the peace, seem also to be remove-
able by the legislature; and the executive power of par-
doning in certain cases to be referred to the same depart-
ment. The members of the executive council are made EX
OFFICIO justices of peace throughout the state.
In Delaware, the chief executive magistrate is annually
elected by the legislative department. The speakers of the
two legislative branches are vice-presidents in the execu-
tive department. The executive chief, with six others, ap-
pointed three by each of the legislative branches, consti-
tute the supreme court of appeals: He is joined with the
legislative department in the appointment of the other
judges. Throughout the states it appears that the members
of the legislature may at the same time be justices of the
peace. In this state, the members of one branch of it are
EX OFFICIO justices of peace; as are also the members of
the executive council. The principal officers of the execu-
tive department are appointed by the legislative; and one
branch of the latter forms a court of impeachments. All
officers may be removed on address of the legislature.
327
Maryland has adopted the maxim in the most unquali-
fied terms; declaring that the legislative, executive and ju-
dicial powers of government, ought to be forever separate
and distinct from each other. Her constitution, notwith-
standing makes the executive magistrate appointable by
the legislative department; and the members of the judi-
ciary, by the executive department.
The language of Virginia is still more pointed on this
subject . Her constitution declares, "that the legislative, ex-
ecutive and judiciary departments, shall be separate and
distinct; so that neither exercise the powers properly be-
longing to the other; nor shall any person exercise the
powers of more than one of them at the same time; except
that the justices of the county courts shall be eligible to
either house of assembly." Yet we find not only this ex-
press exception, with respect to the members of the infe-
rior courts; but that the chief magistrate with his executive
council are appointable by the legislature; that two mem-
bers of the latter are triennially displaced at the pleasure
of the legislature; and that all the principal offices, both
executive and judiciary, are filled by the same department.
The executive prerogative of pardon, also is in one case
vested in the legislative department.
The constitution of North-Carolina, which declares,
"that the legislative, executive and supreme judicial powers
of government, ought to be forever separate and distinct
from each other," refers at the same time to the legislative
department, the appointment not only of the executive
25
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 10, SEPARATION OF POWERS, NO. 15
chief, but all the principal officers within both that and the
judiciary department.
In South-Carolina, the constitution makes the executive
magistracy eligible by the legislative department. It gives
to the latter also the appointment of the members of the
judiciary department, including even justices of the peace
and sheriffs; and the appointment of officers in the exec-
utive department, down to captains in the army and navy
of the state.
In the constitution of Georgia, where it is declared, "that
the legislative, executive and judiciary departments shall
be separate and distinct, so that neither exercise the pow-
ers properly belonging to the other." We find that the ex-
ecutive department is to be filled by appointments of the
legislature; and the executive prerogative of pardon, to be
finally exercised by the same authority. Even justices of the
peace are to be appointed by the legislature.
In citing these cases in which the legislative, executive
and judiciary departments, have not been kept totally sep-
arate and distinct, I wish not to be regarded as an advocate
for the particular organizations of the several state govern-
ments. I am fully aware that among the many excellent
principles which they exemplify, they carry strong marks
of the haste, and still stronger of the inexperience, under
which they were framed. It is but too obvious that in some
instances, the fundamental principle under consideration
has been violated by too great a mixture, and even an ac-
tual consolidation of the different powers; and that in no
instance has a competent provision been made for main-
tammg in practice the separation delineated on paper.
What I have wished to evince is, that the charge brought
against the proposed constitution, of violating a sacred
maxim of free government, is warranted neither by the
real meaning annexed to that maxim by its author; nor by
the sense in which it has hitherto been understood in
America. This interesting subject will be resumed in the
ensuing paper.
15
jAMES MADISON, FEDERALIST, NO. 48, 332-38
1 Feb. 1788
It was shewn in the last paper, that the political apothegm
there examined, does not require that the legislative, ex-
ecutive and judiciary departments should be wholly un-
connected with each other. I shall undertake in the next
place, to shew that unless these departments be so far con-
nected and blended, as to give to each a constitutional con-
troul over the others, the degree of separation which the
maxim requires as essential to a free government, can
never in practice, be duly maintained.
It is agreed on all sides, that the powers properly be-
longing to one of the departments, ought not to be directly
and compleatly administered by either of the other de-
partments. It is equally evident, that neither of them ought
to possess directly or indirectly, an overruling influence
328
over the others in the administration of their respective
powers. It will not be denied, that power is of an encroach-
ing nature, and that it ought to be effectually restrained
from passing the limits assigned to it. After discriminating
therefore in theory, the several classes of power, as they
may in their nature be legislative, executive, or judiciary;
the next and most difficult task, is to provide some practi-
cal security for each against the invasion of the others.
What this security ought to be, is the great problem to be
solved.
Will it be sufficent to mark with precision the bounda-
ries of these departments in the Constitution of the gov-
ernment, and to trust to these parchment barriers against
the encroaching spirit of power? This is the security which
appears to have been principally relied on by the compil-
ers of most of the American Constitutions. But experience
assures us, that the efficacy of the provision has been
greatly over-rated; and that some more adequate defence
is indispensibly necessary for the more feeble, against the
more powerful members of the government. The legisla-
tive department is every where extending the sphere of its
activity, and drawing all power into its impetuous vortex.
The founders of our republics have so much merit for
the wisdom which they have displayed, that no task can be
less pleasing than that of pointing out the errors into
which they have fallen. A respect for truth however
obliges us to remark, that they seem never for a moment
to have turned their eyes from the danger to liberty from
the overgrown and all-grasping prerogative of an heredi-
tary magistrate, supported and fortified by an hereditary
branch of the legislative authority. They seem never to
have recollected the danger from legislative usurpations;
which by assembling all power in the same hands, must
lead to the same tyranny as is threatened by executive
usurpations.
In a government, where numerous and extensive pre-
rogatives are placed in the hands of a hereditary monarch,
the executive department is very justly regarded as the
source of danger, and watched with all the jealousy which
a zeal for liberty ought to inspire. In a democracy, where
a multitude of people exercise in person the legislative
functions, and are continually exposed by their incapacity
for regular deliberation and concerted measures, to the
ambitious intrigues of their executive magistrates, tyranny
may well be apprehended on some favorable emergency,
to start up in the same quarter. But in a representative
republic, where the executive magistracy is carefully lim-
ited both in the extent and the duration of its power; and
where the legislative power is exercised by an assembly,
which is inspired by a supposed influence over the people
with an intrepid confidence in its own strength; which is
sufficiently numerous to feel all the passions which actuate
a multitude; yet not so numerous as to be incapable of
pursuing the objects of its passions, by means which reason
prescribes; it is against the enterprising ambition of this
department, that the people ought to indulge all their jeal-
ousy and exhaust all their precautions.
The legislative department derives a superiority in our
governments from other circumstances. hs constitutional
powers being at once more extensive and less susceptible
26
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
CHAPTER 17, CONSTITUTIONAL GOVERNMENT, NO. 9
Care of their Subjects Health, without being consulted;
and to vomit, bleed, purge, and scarify them at Pleasure,
whether they would or no, just as these established Judges
of Health should think fit? If this were the Case, what a
Stir and Hubbub should we soon see kept about the estab-
lished Potions and Lancets? Every Man, Woman, or Child,
though ever so healthy, must be a Patient, or woe be to
them! The best Diet and Medicines would soon grow per-
nicious from any other Hand; and their Pills alone, how-
ever ridiculous, insufficient, or distasteful, would be at-
tended with a Blessing.
Let People alone, and they will take Care of themselves,
and do it best; and if they do not, a sufficient Punishment
will follow their Neglect, without the Magistrate's Inter-
position and Penalties. It is plain, that such busy Care and
officious Intrusion into the personal Affairs, or private Ac-
tions, Thoughts, and Imaginations of Men, has in it more
Craft than Kindness; and is only a Device to mislead Peo-
ple, and pick their Pockets, under the false Pretence of the
publick and their private Go[o]d. To quarrel with any Man
for his Opinions, Humours, or the Fashion of his Clothes,
is an Offence taken without being given. What is it to a
Magistrate how I wash my Hands, or cut my Corns; what
Fashion or Colours I wear, or what Notions I entertain, or
what Gestures I use, or what Words I pronounce, when
they please me, and do him and my Neighbour no Hurt?
As well may he determine the Colour of my Hair, and
controul my Shape and Features.
True and impartial Liberty is therefore the Right of
every Man to pursue the natural, reasonable, and religious
Dictates of his own Mind; to think what he will, and act as
he thinks, provided he acts not to the Prejudice of an-
other; to spend his own Money himself, and lay out the
Produce of his Labour his own Way; and to labour for his
own Pleasure and Profit, and not for others who are idle,
and would live and riot by pillaging and oppressing him,
and those that are like him.
So that Civil Government is only a partial Restraint put
by the Laws of Agreement and Society upon natural and
absolute Liberty, which might otherwise grow licentious:
And Tyranny is an unlimited Restraint put upon natural
Liberty, by the Will of one or a few. Magistracy, amongst
a free People, is the Exercise of Power for the Sake of the
People; and Tyrants abuse the People, for the Sake of
Power. Free Government is the protecting the People in
their Liberties by stated Rules: Tyranny is a brutish Strug-
gle for unlimited Liberty to one or a few, who would rob
all others of their Liberty, and act by no Rule but lawless
Lust.
9
MoNTESQUIEU, SPIRIT OF LAws, BK. 6, cH. 2;
BK. 11, CHS. 1-7, 20
1748
[Book 6]
2.-0f the Simplicity of Criminal Laws in different
Governments
We hear it generally said thatjustice ought to be admin-
istered with us as in Turkey. Is it possible, then, that the
most ignorant of all nations should be the most clear-
sighted on a point which it most behooves mankind to
know?
If we examine the set forms of justice with respect to
the trouble the subject undergoes in recovering his prop-
erty or in obtaining satisfaction for an injury or affront,
we shall find them doubtless too numerous: but if we con-
sider them in the relation they bear to the liberty and se-
curity of every individual, we shall often find them too
few; and be convinced that the trouble, expense, delays,
and even the very dangers of our judiciary proceedings
are the price that each subject pays for his liberty.
In Turkey, where little regard is shown to the honor,
life, or estate of the subject, all causes are speedily decided.
The method of determining them is a matter of indiffer-
ence, provided they be determined. The pasha, after a
quick hearing, orders which party he pleases to be basti-
nadoed, and then sends them about their business.
Here it would be dangerous to be of a litigious disposi-
tion; this supposes a strong desire of obtaining justice,
a settled aversion, an active mind, and a steadiness in
pursuing one's point. All this should be avoided in a
government where fear ought to be the only prevailing
sentiment, and in which popular disturbances are fre-
quently attended with sudden and unforeseen revolutions.
Here every man ought to know that the magistrate must
not hear his name mentioned, and that his security
depends entirely on his being reduced to a kind of anni-
hilation.
But in moderate governments, where the life of the
meanest subject is deemed precious, no man is stripped of
his honor or property until after a long inquiry; and no
man is bereft of life till his very country has attacked
him-an attack that is never made without leaving him all
possible means of making his defence.
Hence it is that when a person renders himself absolute,
he immediately thinks of reducing the number of laws. In
a government thus constituted they are more affected with
particular inconveniences than with the liberty of the sub-
ject, which is very little minded.
623
In republics, it is plain that as many formalities at least
are necessary as in monarchies. In both governments they
increase in proportion to the value which is set on the
honor, fortune, liberty, and life of the subject.
In republican governments, men are all equal; equal
27
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
I.
I
CHAPTER 17, CONSTITUTIONAL GOVERNMENT, NO. 9
they are also in despotic governments: in the former, be-
cause they are everything; in the latter, because they are
nothing.
[Book 11]
1.-A general Idea
make a distinction between the laws that establish po-
litical liberty as it relates to the constitution, and those by
which it is established as it relates to the citizen. The for-
mer shall be the subject of this book; the latter I shall ex-
amine in the next.
2 .-Different Significations of the word Liberty
There is no word that admits of more various significa-
tions, and has made more varied impressions on the hu-
man mind, than that of liberty. Some have taken it as a
means of deposing a person on whom they had conferred
a tyrannical authority; others for the power of choosing a
superior whom they are obliged to obey; others for the
right of bearing arms, and of being thereby enabled to use
violence; others, in fine, for the privilege of being gov-
erned by a native of their own country, or by their own
laws. A certain nation for a long time thought liberty con-
sisted in the privilege of wearing a long beard. Some have
annexed this name to one form of government exclusive
of others: those who had a republican taste applied it to
this species of polity; those who liked a monarchical state
gave it to monarchy. Thus they have all applied the name
of liberty to the government most suitable to their own
customs and inclinations: and as in republics the people
have not so constant and so present a view of the causes
of their misery, and as the magistrates seem to act only in
conformity to the laws, hence liberty is generally said to
reside in republics, and to be banished from monarchies.
In fine, as in democracies the people seem to act almost as
they please, this sort of government has been deemed the
most free, and the power of the people has been con-
founded with their liberty.
3 .-In what Liberty consists
It is true that in democracies the people seem to act as
they please; but political liberty does not consist in an un-
limited freedom. In governments, that is, in societies di-
rected by laws, liberty can consist only in the power of
doing what we ought to will, and in not being constrained
to do what we ought not to will.
We must have continually present to our minds the dif-
ference between independence and liberty. Liberty is a
right of doing whatever the laws permit, and if a citizen
could do what they forbid he would be no longer pos-
sessed of liberty, because all his fellow-citizens would have
the same power.
4.-The same Subject continued
Democratic and aristocratic states are not in their own
nature free. Political liberty is to be found only in moder-
624
ate governments; and even in these it is not always found.
It is there only when there is no abuse of power. But con-
stant experience shows us that every man invested with
power is apt to abuse it, and to carry his authority as far
as it will go. Is it not strange, though true, to say that vir-
tue itself has need of limits?
To prevent this abuse, it is necessary from the very na-
ture of things that power should be a check to power. A
government may be so constituted, as no man shall be
compelled to do things to which the law does not oblige
him, nor forced to abstain from things which the law per-
mits.
5.-0f the End or View of different Governments
Though all governments have the same general end,
which is that of preservation, yet each has another partic-
ular object. Increase of dominion was the object of Rome;
war, that of Sparta; religion, that of the Jewish laws; com-
merce, that of Marseilles; public tranquility, that of the
laws of China: navigation, that of the laws of Rhodes; nat-
ural liberty, that of the policy of the Savages; in general,
the pleasures of the prince, that of despotic states; that of
monarchies, the prince's and the kingdom's glory; the in-
dependence of individuals is the end aimed at by the laws
of Poland, thence results the oppression of the whole.
One nation there is also in the world that has for the
direct end of its constitution political liberty. We shall
presently examine the principles on which this liberty is
founded; if they are sound, liberty will appear in its high-
est perfection.
To discover political liberty in a constitution, no great
labor is requisite. If we are capable of seeing it where it
exists, it is soon found, and we need not go far in search
of it.
6.-0f the Constitution of England
In every government there are three sorts of power: the
legislative; the executive in respect to things dependent on
the law of nations; and the executive in regard to matters
that depend on the civil law.
By virtue of the first, the prince or magistrate enacts
temporary or perpetual laws, and amends or abrogates
those that have been already enacted. By the second, he
makes peace or war, sends or receives embassies, estab-
lishes the public security, and provides against invasions.
By the third, he punishes criminals, or determines the dis-
putes that arise between individuals. The latter we shall
call the judiciary power, and the other simply the execu-
tive power of the state.
The political liberty of the subject is a tranquillity of
mind arising from the opinion each person has of his
safety. In order to have this liberty, it is requisite the gov-
ernment be so constituted as one man need not be afraid
of another.
When the legislative and executive powers are united in
the same person, or in the same body of magistrates, there
can be no liberty; because apprehensions may arise, lest
the same monarch or senate should enact tyrannical laws,
to execute them in a tyrannical manner.
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Again, there is no liberty, if the judiciary power be not
separated from the legislative and executive. Were it
joined with the legislative, the life and liberty of the subject
would be exposed to arbitrary control; for the judge would
be then the legislator. Were it joined to the executive
power, the judge might behave with violence and oppres-
siOn.
There would be an end of everything, were the same
man or the same body, whether of the nobles or of the
people, to exercise those three powers, that of enacting
laws, that of executing the public resolutions, and of trying
the causes of individuals.
Most kingdoms in Europe enjoy a moderate government
because the prince who is invested with the two first pow-
ers leaves the third to his subjects. In Turkey, where these
three powers are united in the Sultan's person, the subjects
groan under the most dreadful oppression.
In the republics of Italy, where these three powers are
united, there is less liberty than in our monarchies. Hence
their government is obliged to have recourse to as violent
methods for its support as even that of the Turks; witness
the state inquisitors, and the lion's mouth into which every
informer may at all hours throw his written accusations.
In what a situation must the poor subject be in those
republics! The same body of magistrates are possessed, as
executors of the laws, of the whole power they have given
themselves in quality of legislators. They may plunder the
state by their general determinations; and as they have
likewise the judiciary power in their hands, every private
citizen may be ruined by their particular decisions.
The whole power is here united in one body; and
though there is no external pomp that indicates a despotic
sway, yet the people feel the effects of it every moment.
Hence it is that many of the princes of Europe, whose
aim has been levelled at arbitrary power, have constantly
set out with uniting in their own persons all the branches
of magistracy, and all the great offices of state.
I allow indeed that the mere hereditary aristocracy of
the I tali an republics does not exactly answer to the des-
potic power of the Eastern pr!nces. The number of mag-
istrates sometimes moderate the power of the magistracy;
the whole body of the nobles do not always concur in the
same design; and different tribunals are erected, that tem-
per each other. Thus at Venice the legislative power is in
the council, the executive in the pregadi, and the judiciary
in the quarantia. But the mischief is, that these different
tribunals are composed of magistrates all belonging to the
same body; which constitutes almost one and the same
power.
The judiciary power ought not to be given to a standing
senate; it should be exercised by persons taken from the
body of the people at certain times of the year, and consis-
tently with a form and manner prescribed by law, in order
to erect a tribunal that should last only so long as necessity
requires.
By this method the judicial power, so terrible to man-
kind, not being annexed to any particular state or profes-
sion, becomes, as it were, invisible. People have not then
the judges continually present to their view; they fear the
office, but not the magistrate.
In accusations of a deep and criminal nature, it is
proper the person accused should have the privilege of
choosing, in some measure, his judges, in concurrence
with the law; or at least he should have a right to except
against so great a number that the remaining part may be
deemed his own choice.
The other two powers may be given rather to magis-
trates or permanent bodies, because they are not exercised
on any private subject; one being no more than the gen-
eral will of the state, and the other the execution of that
general will.
But though the tribunals ought not to be fixed, the
judgments ought; and to such a degree as to be ever con-
formable to the letter of the law. Were they to be the
private opinion of the judge, people would then live in
society, without exactly knowing the nature of their obli-
gations.
The judges ought likewise to be of the same rank as the
accused, or, in other words, his peers; to the end that he
may not imagine he is fallen into the hands of persons
inclined to treat him with rigor.
If the legislature leaves the executive power in posses-
sion of a right to imprison those subjects who can give se-
curity for their good behavior, there is an end of liberty;
unless they are taken up, in order to answer without delay
to a capital crime, in which case they are really free, being
subject only to the power of the law.
But should the legislature think itself in danger by some
secret conspiracy against the state, or by a correspondence
with a foreign enemy, it might authorize the executive
power, for a short and limited time, to imprison suspected
persons, who in that case would lose their liberty only for
a while, to preserve it forever.
625
And this is the only reasonable method that can be sub-
stituted to the tyrannical magistracy of the Ephori, and to
the state inquisitors of Venice, who are also despotic.
As in a country of liberty, every man who is supposed a
free agent ought to be his own governor; the legislative
power should reside in the whole body of the people. But
since this is impossible in large states, and in small ones is
subject to many inconveniences, it is fit the people should
transact by their representatives what they cannot transact
by themselves.
The inhabitants of a particular town are much better
acquainted with its wants and interests than with those of
other places; and are better judges of the capacity of their
neighbors than of that of the rest of their countrymen.
The members, therefore, of the legislature should not be
chosen from the general body of the nation; but it is
proper that in every considerable place a representative
should be elected by the inhabitants.
The great advantage of representatives is, their capacity
of discussing public affairs. For this the people collectively
are extremely unfit, which is one of the chief inconve-
niences of a democracy.
It is not at all necessary that the representatives who
have received a general instruction from their constituents
should wait to be directed on each particular affair, as is
practised in the diets of Germany. True it is that by this
way of proceeding the speeches of the deputies might with
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greater propriety be called the voice of the nation; but, on
the other hand, this would occasion infinite delays; would
give each deputy a power of comrolling the assembly; and,
on the most urgent and pressing occasions, the wheels of
government might be stopped by the caprice of a single
person.
When the deputies, as Mr. Sidney well observes, repre-
sent a body of people, as in Holland, they ought to be
accountable to their constituents; but it is a different thing
in England, where they are deputed by boroughs.
All the inhabitants of the several districts ought to have
a right of voting at the election of a representative, except
such as are in so mean a situation as to be deemed to have
no will of their own.
One great fault there was in most of the ancient repub-
lics, that the people had a right to active resolutions, such
as require some execution, a thing of which they are ab-
solutely incapable. They ought to have no share in the
government but for the choosing of representatives, which
is within their reach. For though few can tell the exact
degree of men's capacities, yet there are none but are ca-
pable of knowing in general whether the person they
choose is better qualified than most of his neighbors.
Neither ought the representative body to be chosen for
the executive part of government, for which it is not so fit;
but for the enacting of laws, or to see whether the laws in
being are duly executed, a thing suited to their abilities,
and which none indeed but themselves can properly per-
form.
In such a state there are always persons distinguished by
their birth, riches, or honors; but were they to be con-
founded with the common people, and to have only the
weight of a single vote like the rest, the common liberty
would be their slavery, and they would have no interest in
supporting it, as most of the popular resolutions would be
against them. The share they have, therefore, in the leg-
islature ought to be proportioned to their other advan-
tages in the state; which happens only when they form a
body that has a right to check the licentioJsness of the
people, as the people have a right to oppose any encroach-
ment of theirs.
The legislative power is therefore committed to the body
of the nobles, and to that which represents the people,
each having their assemblies and deliberations apart, each
their separate views and interests.
Of the three powers above mentioned, the judiciary is in
some measure next to nothing: there remain, therefore,
only two; and as these have need of a regulating power to
moderate them, the part of the legislative body composed
of the nobility is extremely proper for this purpose.
The body of the nobility ought to be hereditary. In the
first place it is so in its own nature; and in the next there
must be a considerable interest to preserve its privileges-
privileges that in themselves are obnoxious to popular
envy, and of course in a free state are always in danger.
But as a hereditary power might be tempted to pursue
its own particular interests, and forget those of the people,
it is proper that where a singular advantage may be gained
by corrupting the nobility, as in the laws relating to the
626
supplies, they should have no other share in the legislation
than the power of rejecting, and not that of resolving.
By the power of resolving I mean the right of ordaining
by their own authority, or of amending what has been or-
dained by others. By the power of rejecting I would be
understood to mean the right of annulling a resolution
taken by another; which was the power of the tribunes at
Rome. And though the person possessed of the privilege
of rejecting may likewise have the right of approving, yet
this approbation passes for no more than a declaration,
that he intends to make no use of his privilege of rejecting,
and is derived from that very privilege.
The executive power ought to be in the hands of a mon-
arch, because this branch of government, having need of
despatch, is better administered by one than by many: on
the other hand, whatever depends on the legislative power
is oftentimes better regulated by many than by a single
person.
But if there were no monarch, and the executive power
should be committed to a certain number of persons se-
lected from the legislative body, there would be an end
then of liberty; by reason the two powers would be united,
as the same persons would sometimes possess, and would
be always able to possess, a share in both.
Were the legislative body to be a considerable time with-
out meeting, this would likewise put an end to liberty. For
of two things one would naturally follow: either that there
would be no longer any legislative resolutions, and then
the state would fall into anarchy; or that these resolutions
would be taken by the executive power, which would ren-
der it absolute.
It would be needless for the legislative body to continue
always assembled. This would be troublesome to the rep-
resentatives, and, moreover, would cut out too much work
for the executive power, so as to take off its attention to
its office, and oblige it to think only of defending its own
prerogatives, and the right it has to execute.
Again, were the legislative body to be always assembled,
it might happen to be kept up only by filling the places of
the deceased members with new representatives; and in
that case, if the legislative body were once corrupted, the
evil would be past all remedy. When different legislative
bodies succeed one another, the people who have a bad
opinion of that which is actually sitting may reasonably en-
tertain some hopes of the next: but were it to be always
the same body, the people upon seeing it once corrupted
would no longer expect any good from its laws; and of
course they would either become desperate or fall into a
state of indolence.
The legislative body should not meet of itself. For a
body is supposed to have no will but when it is met; and
besides, were it not to meet unanimously, it would be im-
possible to determine which was really the legislative body;
the part assembled, or the other. And if it had a right to
prorogue itself, it might happen never to be prorogued;
which would be extremely dangerous, in case it should
ever attempt to encroach on the executive power. Besides,
there are seasons, some more proper than others, for as-
sembling the legislative body: it is fit, therefore, that the
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executive power should regulate the time of meeting, as
well as the duration of those assemblies, according to the
circumstances and exigencies of a state known to itself.
Were the executive power not to have a right of re-
straining the encroachments of the legislative body, the
latter would become despotic; for as it might arrogate to
itself what authority it pleased, it would soon destroy all
the other powers.
But it is not proper, on the other hand, that the legisla-
tive power should have a right to stay the executive. For
as the execution has its natural limits, it is useless to con-
fine it; besides, the executive power is generally employed
in momentary operations. The power, therefore, of the
Roman tribunes was faulty, as it put a stop not only to the
legislation, but likewise to the executive part of govern-
ment; which was attended with infinite mischief.
But if the legislative power in a free state has no right
to stay the executive, it has a right and ought to have the
means of examining in what manner its laws have been
executed; an advantage which this government has over
that of Crete and Sparta, where the Cosmi and the Ephori
gave no account of their administration.
But whatever may be the issue of that examination, the
legislative body ought not to have a power of arraigning
the person, nor, of course, the conduct, of him who is in-
trusted with the executive power. His person should be
sacred, because as it is necessary for the good of the state
to prevent the legislative body from rendering themselves
arbitrary, the moment he is accused or tried there is an
end of liberty.
In this case the state would be no longer a monarchy,
but a kind of republic, though not a free government. But
as the person intrusted with the executive power cannot
abuse it without bad counsellors, and such as have the laws
as ministers, though the laws protect them as subjects,
these men may be examined and punished-an advantage
which this government has over that of Gnidus, where the
law allowed of no such thing as calling the Amymones to
an account, even after their administration; and therefore
the people could never obtain any satisfaction for the in-
juries done them.
Though, in general, the judiciary power ought not to be
united with any part of the legislative, yet this is liable to
three exceptions, founded on the particular interest of the
party accused.
The great are always obnoxious to popular envy; and
were they to be judged by the people, they might be in
danger from their judges, and would, moreover, be de-
prived of the privilege which the meanest subject is pos-
sessed of in a free state, of being tried by his peers. The
nobility, for this reason, ought not to be cited before the
ordinary courts of judicature, but before that part of the
legislature which is composed of their own body.
It is possible that the law, which is clear sighted in one
sense, and blind in another, might, in some cases, be too
severe. But as we have already observed, the national
judges are no more than the mouth that pronounces the
words of the law, mere passive beings, incapable of mod-
erating either its force or rigor. That part, therefore, of
the legislative body, which we have just now observed to
be a necessary tribunal on another occasion, also is a nec-
essary tribunal in this; it belongs to its supreme authority
to moderate the law in favor of the law itself, by mitigating
the sentence.
It might also happen that a subject intrusted with the
administration of public affairs may infringe the rights of
the people, and be guilty of crimes which the ordinary
magistrates either could not or would not punish. But, in
general, the legislative power cannot try causes: and much
less can it try this particular case, where it represents the
party aggrieved, which is the people. It can only, there-
fore, impeach. But before what court shall it bring its
impeachment? Must it go and demean itself before the
ordinary tribunals, which are its inferiors, and, being com-
posed, moreover, of men who are chosen from the people
as well as itself, will naturally be swayed by the authority
of so powerful an accuser? No: in order to preserve the
dignity of the people and the security of the subject, the
legislative part which represents the people must bring in
its charge before the legislative part which represents the
nobility, who have neither the same interests nor the same
passions.
Here is an advantage which this government has over
most of the ancient republics, where this abuse prevailed,
that the people were at the same time both judge and ac-
cuser.
The executive power, pursuant of what has been already
said, ought to have a share in the legislature by the power
of rejecting; otherwise it would soon be stripped of its pre-
rogative. But should the legislative power usurp a share of
the executive, the latter would be equally undone.
If the prince were to have a part in the legislature by
the power of resolving, liberty would be lost. But as it is
necessary he should have a share in the legislature for the
support of his own prerogative, this share must consist in
the power of rejecting.
The change of government at Rome was owing to this,
that neither the senate, who had one part of the executive
power, nor the magistrates, who were intrusted with the
other, had the right of rejecting, which was entirely lodged
in the people.
627
Here, then, is the fundamental constitution of the gov-
ernment we are treating of. The legislative body being
composed of two parts, they check one another by the mu-
tual privilege of rejecting. They are both restrained by the
executive power, as the executive is by the legislative.
These three powers should naturally form a state of re-
pose or inaction. But as there is a necessity for movement
in the course of human affairs, they are forced to move,
but still in concert.
As the executive power has no other part in the legisla-
tive than the privilege of rejecting, it can have no share in
the public debates. It is not even necessary that it should
propose, because as it may always disapprove of the reso-
lutions that shall be taken, it may likewise reject the deci-
sions on those proposals which were made against its will.
In some ancient commonwealths, where public debates
were carried on by the people in a body, it was natural for
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the executive power to propose and debate in conjunction
with the people, otherwise their resolutions must have
been attended with a strange confusion.
Were the executive power to determine the raising of
public money, otherwise than by giving its consent, liberty
would be at an end; because it would become legislative in
the most important point of legislation.
If the legislative power was to settle the subsidies, not
from year to year, but forever, it would run the risk of
losing its liberty, because the executive power would be no
longer dependent; and when once it was possessed of such
a perpetual right, it would be a matter of indifference
whether it held it of itself or of another. The same may be
said if it should come to a resolution of intrusting, not an
annual, but a perpetual command of the fleets and armies
to the executive power.
To prevent the executive power from being able to op-
press, it is requisite that the armies with which it is in-
trusted should consist of the people, and have the same
spirit as the people, as was the case at Rome till the time
of Marius. To obtain this end, there are only two ways,
either that the persons employed in the army should have
sufficient property to answer for their conduct to their fel-
low-subjects, and be enlisted only for a year, as was cus-
tomary at Rome; or if there should be a standing army,
composed chiefly of the most despicable part of the nation,
the legislative power should have a right to disband them
as soon as it pleased; the soldiers should live in common
with the rest of the people; and no separate camp, bar-
racks, or fortress should be suffered.
When once an army is established, it ought not to de-
pend immediately on the legislative, but on the executive
power; and this from the very nature of the thing, its busi-
ness consisting more in action than in deliberation.
It is natural for mankind to set a higher value upon
courage than timidity, on activity than prudence, on
strength than counsel. Hence the army will ever despise a
senate, and respect their own officers. They will naturally
slight the orders sent them by a body of men whom they
look upon as cowards, and therefore unworthy to com-
mand them. So that as soon as the troops depend entirely
on the legislative body, it becomes a military government;
and if the contrary has ever happened, it has been owing
to some extraordinary circumstances. It is because the
army was always kept divided; it is because it was com-
posed of several bodies that depended each on a particular
province: it is because the capital towns were strong places,
defended by their natural situation, and not garrisoned
with regular troops. Holland, for instance, is still safer
than Venice; she might drown or starve the revolted
troops; for as they are not quartered in towns capable of
furnishing them with necessary subsistence, this subsist-
ence is of course precarious.
In perusing the admirable treatise of Tacitus "On the
Manners of the Germans," we find it is from that nation
the English have borrowed the idea of their political gov-
ernment. This beautiful system was invented first in the
woods.
As all humans things have an end, the state we are
speaking of will lose its liberty, will perish. Have not Rome,
628
Sparta, and Carthage perished? It wi ll perish when the
legislative power shall be more corrupt than the executive.
It is not my business to examine whether the English
actually enjoy this liberty or not. Sufficient it is for my pur-
pose to observe that it is established by their laws; and I
inquire no further.
Neither do I pretend by this to undervalue other gov-
ernments, nor to say that this extreme political liberty
ought to give uneasiness to those who have only a moder-
ate share of it. How should I have any such design, I who
think that even the highest refinement of reason is not al-
ways desirable, and that mankind generally find their ac-
count better in mediums than in extremes?
Harrington, in his "Oceana," has also inquired into the
utmost degree of liberty to which the constitution of a state
may be carried. But of him, indeed, it may be said that for
want of knowing the nature of real liberty he busied him-
self in pursuit of an imaginary one; and that he built a
Chalcedon, though he had a Byzantium before his eyes.
7.-0f the Monarchies we are acquainted with
The monarchies we are acquainted with have not, like
that we have been speaking of, liberty for their direct view:
the only aim is the glory of the subject, of the state, and of
the sovereign. But hence there results a spirit of liberty,
which in those states is capable of achieving as great
things, and of contributing as much, perhaps, to happi-
ness, as liberty itself.
Here the three powers are not distributed and founded
on the model of the constitution above mentioned; they
have each a particular distribution, according to which
they border more or less on political liberty; and if they
did not border upon it, monarchy would degenerate into
despotic government.
20.-The End of this Book
I should be glad to inquire into the distribution of the
three powers, in all the moderate governments we are ac-
quainted with, in order to calculate the degrees of liberty
which each may enjoy. But we must not always exhaust a
subject, so as to leave no work at all for the reader. My
business is not to make people read, but to make them
think.
10
RICHARD HENRY LEE TO ---
31 May 1764
Letters 1:5-7
Many late determinations of the great, on your side of the
water, seem to prove a resolution, to oppress North Amer-
ica with the iron hand of power, unrestrained by any sen-
timent, drawn from reason, the liberty of mankind, or the
genius of their own government. 'Tis said the House of
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1 r
RoMANS 1
Greek New Testament
TIPOL: POMAIOYL:
1
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d.wpLCTilEVOS' de; EJJayyEALOV 8Eou, 2 o npoEnTJyydA.aTo
8u1 TWV npoTJTWV QlJTOU EV ypaciic; ay(mc; 3 1TEpl TOU
uLou mhou Tou yEVO!lEvou EK crnEPilaToc; Kma crcipKa,
4 Tou 6pw8EvToc; ulou 8Eou v 8uvci11EL KaTa nvEiilla
ayLWCTUVTJS' d.vaCTTclCTEWS' VEKploV, 'ITJCTOU XpLCTTOU TOU
KUpLOU TJill;:lV, 5 8L' ou xcipLV Kal d.noaTOAT]V ELS'
imaKoi]v TTLCTTEWS' v niicrw TOLS' E!evww imE:p Tou 6v611aTOS'
UlJTOU, 6 EV oLS' ECTTE KUL UllELS' KATJTOL 'ITJCTOU XpLCTTOU,
7 TT<ICTLV TOLS' Ol!CTLV EV 'PW!lTJ d.yaTTTJTolS' 8EOU, KATJTolS' ay(-
OLS', xcipLS' u!l'Lv KUL d.no 8EOU naTpoc; TJilWV KUL
Kup[ou 'ITJCTOU XpwTou.
s npwTov
11
E:v El!xapwTw T0 8E0 11ou aLa 'ITJcroD XpwTou
nEpl. ncivTwv UllWV on i] TTLCTTLS' UllWV KaTayyEAAETaL Ev
OA4J Tl\> KOCTil4l 9 llclPTUS' ycip !lOU ECTTLV 6 8EOS', tV
AaTpEUW EV Tl\> TTVEU!lUTL !lOU EV T0 EuayyEAL4J TOU ui.ou
avTov, we; d.8wA.dnTWS' llVEtav UllWV TTOLOU!laL 10 ncivTOTE
nl. Twv npocrEuxwv !lOU OEO!lEVOS' EL nwc; noTE
EV T0 TOU 8EOU EA8ELV npoc; UlliiS'.
11 m no8w yap t8E'Lv u11iis, '[va n llEm8w xcipwiJ.a ViJ.'lv
TTVEUIJ.UTLKOV Etc; TO UIJ.US', 12 TOUTO OE ECTTLV
Amplified Bible
THE LETTER OF PAUL TO THE
ROMANS
1
FROM PAUL, a bond servant of jesus Christ (the Messiah)
called to be an apostle, (a special messenger) set apart to
[preach] the Gospel (good news) of and from God,
2 Which He promised in advance [long ago] through His
prophets in the sacred Scriptures-
3 [The Gospel] regarding His Son, Who as to the flesh (His
human nature) was descended from David,
4 And [as to His divine nature] according to the Spirit of holi-
ness was openly adesignated the Son of God in power [in a strik-
ing, triumphant and miraculous manner] by His resurrection
from the dead, even jesus Christ our Lord (the Messiah, the
Anointed One).
5 It is through Him that we have received grace (God's unmerit-
ed favor) and [our] apostleship to promote obedience to the faith
and make disciples for His name's sake among all the nations,
6 And this includes you, called of jesus Christ and invited [as
you are] to belong to Him.
7 To [You then] all God's beloved ones in Rome, called to be
saints and designated for a consecrated life: Grace and spiritual
blessing and peace be yours from God our Father and from the
Lord jesus Christ.
8 First, 1 thank my God through jesus Christ for all of you,
because [the report your faith is made known to all the world
and is bcommended everywhere.
9 For God is my witness, Whom 1 serve with my [whole] spirit
[rendering priestly and spiritual service] in [preaching] the Gospel
and [telling] the good news of His Son, how incessantly 1 always
mention you when at my prayers.
10 1 keep pleading that somehow by God's will I may now at
last prosper and come to you.
11 For 1 am yearning to see you, that 1 may impart and share
with you some spiritual gift to strengthen and establish you;
792
King }ames Version
THE EPISTLE OF ST. PAUL TO THE
ROMANS
1
Paul, a servant of jesus Christ, called to be an apostle. sepa-
rated unto the gospel of God,
2 (Which he had promised afore by his prophets in the holy
scriptures,)
3 Concerning his Son jesus Christ our Lord, which was made
of the seed of David according to the flesh;
4 And declared to be the Son of God with power, according to
the spirit of holiness, by the resurrection from the dead:
5 By whom we have received grace and apostleship, for obedi-
ence ro the faith among all nations, for his name:
6 Among whom are ye also the called of jesus Christ:
7 To all that be in Rome, beloved of God, called to be saints:
Grace to you and peace from God our Father, and the Lord jesus
Christ.
8 First, 1 thank my God through jesus Christ for you all, that
your faith is spoken of throughout the whole world.
9 For God is my witness, whom 1 serve with my spirit in the
gospel of his Son, that without ceasing 1 make mention of you
always in my prayers;
10 Making request, if by any means now at length I might
have a prosperous journey by the will of God to come unto you.
11 For I long to see you, that I may impart unto you some
spiritual gift, to the end ye may be established;
Rheims New Testament
THE EPISTLE OF ST. PAUL TO THE
ROMANS
1
Paul, a servant of jesus Christ, called to be an apostle, sepa-
rated unto the gospel of God,
2 Which he had promised before, by his prophets, in the holy
scriptures,
3 Concerning his Son, who was made to him of the seed of
David, according to the flesh,
4 Who was predestinated the Son of God in power, according
to the spirit of sanctification, by the resurrection of our Lord
jesus Christ from the dead;
5 By whom we have received grace and apostleship for obedi-
ence to the faith, in all nations, for his name;
6 Among whom are you also the called of jesus Christ:
7 To all that are at Rome, the beloved of God, called to be
saints. Grace to you, and peace from God our Father, and from
the Lord jesus Christ.
8 First 1 give thanks to my God, through jesus Christ, for you
all, because your faith is spoken of in the whole world.
9 For God is my witness, whom 1 serve in my spirit in the
gospel of his Son, that without ceasing I make a commemoration
of you;
10 Always in my prayers making request, if by any means
now at length I may have a prosperous journey, by the will of
God, to come unto you.
11 For I long to see you, that I may impart unto you some
spiritual grace, to strengthen you:
AB: a Marvin Vincent, Word Studies in the New Testament. b Marvin
Vincent, Word Studies in the New Testament.
36
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
793
New American Standard Bible
THE EPISTLE OF PAUL TO THE
ROMANS
1
Paul, a bond-servant of Christ jesus, called as an apostle, set
apart for the gospel of God,
2 which He promised beforehand through His prophets in the
holy Scriptures,
3 concerning His Son, who was born of a descendant cif David
according to the flesh,
4 who was declared the Son of God with power 'by the resur-
rection from the dead, accordi ng to the Spirit of holiness, jesus
christ our Lord,
5 through whom we have received grace and apostleship to
bring about the obedience of faith among all the Gentiles, for His
name's sake,
6 among whom you also are the called of jesus Christ;
' 7 to all who are beloved of God in Rome, called as saints: Grace
to you and peace from God our Father and the Lord jesus Christ.
s First, I thank my God through jesus Christ for you all,
because your faith is being proclaimed throughout the whole
world.
9 For God, whom I serve in my spirit in the preaching if the
gospel of His Son, is my witness as to how unceasingly I make
mention ofyou,
10 always in my prayers making request, if perhaps now at last
by the will of God I may succeed in coming to you.
11 For I long to see you in order that I may impart some spiritu-
al gift to you, that you may be established;
1 Or, as a result qf
New American Bible
THE LETTER TO THE
ROMANS
1
Paul, a slave of Christ jesus, called to be an apostle and set
1
apart for the gospel of God, 2which he promised previously
through his prophets in the holy scriptures, 3the gospel about his
Son, descended from David according to the flesh, 4but estab-
lished as Son of God in power according to the spirit of holiness
through resurrection from the dead, jesus Christ our Lord.
SThrough him we have received the grace of apostleship, to bring
about the obedience of faith, for the sake of his name, among all
the Gentiles, 6among whom are you also, who are called to
belong to jesus Christ; 7to all the beloved of God in Rome, called
to be holy. Grace to you and peace from God our Father and the
Lord jesus Christ.
Bfirst, I give thanks to my God through jesus Christ for all of
you, because your faith is heralded throughout the world. 9God is
my witness, whom I serve with my spirit in proclaiming the gospel
of his Son, that I remember you constantly, toaJways asking in
my prayers that somehow by God's will I may at last find my way
clear to come to you. ttfor I long to see you, that I may share
with you some spiritual gift so that you may be strengthened,
ROMANS 1
New International Version
ROMANS
1
Paul, a servant of Christ jesus, called to be an apostle and set
apart for the gospel of God- 2the gospel he promised before-
hand through his prophets in the Holy Scriptures 3regarding his
Son, who as to his human nature was a descendant of David,
4and who through the Spirita of holiness was declared with
power to be the Son of Godb by his resurrection from the dead:
jesus Christ our Lord. SThrough him and for his name's sake, we
received grace and apostleship to call people from among all the
Gentiles to the obedience that comes from faith. 6And you also
are among those who are called to belong to jesus Christ.
7To all in Rome who are loved by God and called to be saints:
Grace and peace to you from God our Father and from the Lord
jesus Christ.
Bfirst, I thank my God through jesus Christ for all of you,
because your faith is being reported all over the world. 9God,
whom I serve with my whole heart in preaching the gospel of his
Son, is my witness how constantly I remember you toi n my
prayers at all times; and I pray that now at last by God's will the
way may be opened for me to come to you.
11 I long to see you so that I may impart to you some spiritual
gift to make you strong- t2that is , that you and I may be mutu-
a 4 Or who as to his spirit b 4 Or was appointed to be the Son qf God with
power
New Revised Standard Version
THE LETTER_OF PAUL TO THE
ROMANS
1
Paul, a servanta of jesus Christ, called to be an apostle, set
apart for the gospel of God, 2which he promised beforehand
through his prophets in the holy scriptures, 3the gospel concern-
ing his Son, who was descended from David according to the
flesh 4and was declared to be Son of God with power according
to the spiritb of holiness by resurrection from the dead, jesus
Christ our Lord, sthrough whom we have received grace and
apostleship to bring about the obedience of faith among all the
Gentiles for the sake of his name, 6including yourselves who are
called to belong to jesus Christ,
7 To all God's beloved in Rome, who are called to be saints:
Grace to you and peace from God our Father and the Lord jesus
Christ.
8 First, I thank my God through jesus Christ for all of you,
because your faith is proclaimed throughout the world. 9for God,
whom I serve with my spirit by announcing the gospelc of his
Son, is my witness that without ceasing I remember you always
in my prayers, toasking that by God's will I may somehow at last
succeed in coming to you. ttfor I am longing to see you so that I
may share with you some spiritual gift to strengthen you- t2or
a Gk stave b Or Spzlit c Gk my spiri in the gospel
37
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
1 CORINTHIANS 1
Greek New Testament
TTP02: KOPIN8IOY2: A
1
TiauAos- KAr]TOS' cim)aToAos- XpwToiJ ' IT]aou 8u1
IWTOS' 8EOu Kal L:wa8EVT]S' 6 ci8EAos- 2 EKKAT]a[q
Tou 8Eou Ti] ova\] EV Kop[v84J , EV
'ITjaOV, KA'rjTOLS' ayLOLS', aiw TrQULV Tciis ETTLKaAOU!lEVOLS' TO
ovo11a TOU Kup[ou ' IT]aou XpwTou EV TiavTl TOTI4J,
QlJTWV KQL 3 xcipLS' U!lLV KQL ciTio 8EOU
TiaTpos- Kal Kup[ou 'IT]aou XpwTou.
4 EuxapwTw T0 8E0
11
ou mivToTE nEpl u11wv ETil TlJ xci-
PLTL TOU 8EOU TlJ 8o8da\] u!llv EV XpwT0 'IT]OOU, 5 OTL EV
TfQVTL ETIAOUTL08T]TE EV EV TIOVTL Acly4J KQL TfclO\]
yvwaEL , 6 Ka8ws- To llapTupLov Tou XpwTou Ev
Ull-LV, 7 WGTE Ull-QS' llil UGTEpELG8m EV !lT]8EVL xapLG!lOTl
ciTIEKOEXO!lEVOUS' Tilv ciTioKciAuljnv TOU Kup[ou 'IT]aou
XpwTou 8 os- Kal. u11as- Ews- TEAous
Tous- EV Tfj Tou Kup[ou 'IT]aou [XpwTou].
9 maTos 6 8E6s, 8L ou EKAi]8T]TE ELS Kmvwv[av Tou uiou
a{nou 'IT]aou XpwTou Tou Kup[ou
Amplified Bible
THE FIRST LEITER OF PAUL TO THE
CORINTHIANS
1
PAUL, SUMMONED by the will and purpose of God to be an
apostle (special messenger) of Christ jesus, and our brother
Sosthenes,
2 To the church (assembly) of God which is in Corinth, to
those consecrated and purified and made holy in Christ Jesus,
[who are] selected and called to be saints (God's people), together
with all those who in any place call upon and give honor to the
name of our Lord Jesus Christ, both their Lord and ours:
3 Grace (favor and spiritual blessing) be to you and [heart]
peace from God our Father and the Lord jesus Christ.
4 I thank my God at all times for you because of the grace (the
favor and spiritual blessing) of God which was bestowed on you
in Christ Jesus,
5 [So] that in Him in every respect you were enriched, in full
power and readiness of speech [to speak of your faith] and com-
plete knowledge arid illumination [to give you full insight into its
meaning].
6 In this way [our] witnessing concerning Christ (the Messiah)
was so confirmed and established and made sure in you
7 That you are not [consciously] falling behind or lacking in
any special spiritual endowment or Christian grace [athe reception
of which is due to the power of divine grace operating in your
souls by the Holy Spirit], while you wait and watch [constantly
living in hope] for the coming of our Lord jesus Christ and [His]
being made visible to all.
8 And He will establish you to the end [keep you steadfast,
give you strength, and guarantee your vindication; He will be
your warrant against all accusation or indictment so that you
will be] guiltless and irreproachable in the day of our Lord jesus
Christ (the Messiah).
9 God is faithful (reliable, trustworthy, and therefore ever true
to His promise, and He can be depended on); by Him you were
872
King }ames Version
THE FIRST EPISTLE OF ST. PAUL TO THE
CORINTHIANS
1
Paul, called to be an apostle of jesus Christ through the will
of God, and Sosthenes our brother,
2 Unto the church of God which is at Corinth, to them that are
sanctified in Christ jesus, called to be saints, with all that in every
place call upon the name of Jesus Christ our Lord. both theirs and
ours:
3 Grace be unto you, and peace, from God our Father, and
.from the Lord jesus Christ.
4 I thank my God always on your behalf, for the grace of God
which is given you by jesus Christ;
5 That in every thing ye are enriched by him, in all utterance,
and in all knowledge;
6 Even as the testimony of Christ was confirmed in you:
7 So that ye come behind in no gift ; waiting for the coming of
our Lord jesus Christ:
8 Who shall also confirm you unto the end, that ye may be
blameless in the day of our Lord jesus Christ.
9 God is faithful, by whom ye were called unto the fellowship
of his Son jesus Christ our Lord.
Rheims New Testament
THE FIRST EPISTLE OF ST. PAUL TO THE
CORINTHIANS
1
Paul, called to be an apostle of jesus Christ by the will of God,
and Sosthenes a brother,
2 To the church of God that is at Corinth, to them that are
sanctified in Christ jesus, called to be saints, with all that invoke
the name of our Lord jesus Christ, in every place of theirs and
ours.
3 Grace to you, and peace from God our Father, and from the
Lord jesus Christ.
4 I give thanks to my God always for you, for the grace of God
that is given you in Christ jesus,
5 That in all things you are made rich in him, in all utterance,
and in all knowledge;
6 As the testimony of Christ was confirmed in you,
7 So that nothing is wanting to you in any grace, waiting for
the manifestation of our Lord jesus Christ.
8 Who also will confirm you unto the end without crime, in
the day of the coming of our Lord jesus Christ.
9 God is faithful: by whom you are called unto the fellowship
of his Son jesus Christ our Lord.
AB: a joseph Thayer, A Greek-English Lexicon Q( the New Testament.
38
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
873
New American Standa rd Bible
THE FIRST EPISTLE OF PAUL TO THE
CORINTHIANS
1
Paul, called as an apostle of jesus Christ by the will of God,
and Sosthenes our brother,
2 to the church of God which is at Corinth, to those who have
been sanctified in Christ jesus, saints by calling, with all who in
every place call upon the name of our Lord jesus Christ, their
Lord and ours:
3 Grace to you and peace from God our Father and the Lord
jesus Christ.
4 I thank Jmy God always concerning you, for the grace of God
which was given you in Christ jesus,
5 that in everything you were enriched in Him, in all speech
and all knowledge,
6 even as the testimony concerning Christ was confirmed in
you,
7 so that you are not lacking in any gift, awaiting eagerly the
revelation of our Lord jesus Christ,
8 who shall also confirm you to the end, blameless in the day
of our Lord jesus Christ.
9 God is faithful, through whom you were called into fellow-
ship with His Son, jesus Christ our Lord.
1 Some ancient mss. do not contain my
New American Bible
THE FIRST LETTER TO THE
CORINTHIANS
1
Paul, called to be an apostle of Christ jesus by the will of God,
and Sosthenes our brother, 2to the church of God that is in
Corinth, to you who have been sanctified in Christ jesus, called to
be holy, with all those everywhere who call upon the name of our
Lord jesus Christ, their Lord and ours. 3Grace to you and peace
from God our Father and the Lord jesus Christ.
4I give thanks to my God always on your account for the grace
of God bestowed on you in Christ jesus, 5that in him you were
enriched in every way, with all discourse and all knowledge, 6as
the testimony to Christ was confirmed among you, 7so that you
are not lacking in any spiritual gift as you wait for the revelation
of our Lord jesus Christ. SHe will keep you firm to the end, irre-
proachable on the day of our Lord jesus [Christ]. 9God is faithful,
~ n by him you were called to fellowship with his Son, jesus
Christ our Lord.
1 CORINTHIANS 1
New Interna tional Version
1 CORINTHIANS
1
Paul, called to be an apostle of Christ jesus by the will of God,
and our brother Sosthenes,
2To the church of God in Corinth, to those sanctified in Christ
jesus and called to be holy, together with all those everywhere
who call on the name of our Lord jesus Christ-their Lord and
ours:
3Grace and peace to you from God our Father and the Lord
jesus Christ.
4I always thank God for you because of his grace given you in
Christ jesus. 5for in him you have been enriched in every way-
in all your speaking and in all your knowledge- 6because our
testimony about Christ was confirmed in you. ?Therefore you do
not lack any spiritual gift as you eagerly wait for our Lord jesus
Christ to be revealed. BHe will keep you strong to the end, so that
you will be blameless on the day of our Lord jesus Christ. 9God,
who has called you into fellowship with his Son jesus Christ our
Lord, is faithful.
New Revised Standard Version
THE FIRST LETTER OF PAUL TO THE
CORINTHIANS
1
Paul, called to be an apostle of Christ jesus by the will of God,
and our brother Sosthenes,
2 To the church of God that is in Corinth, to those who are
sanctified in Christ jesus, called to be saints, together with all
those who in every place call on the name of our Lord jesus
Christ, both their Lorda and ours:
3 Grace to you and peace from God our Father and the Lord
jesus Christ.
4 I give thanks to myb God always for you because of the grace
of God that has been given you in Christ jesus, 5for in every way
you have been enriched in him, in speech and knowledge of every
kind- 6just as the testimony ofc Christ has been strengthened
among you- 7so that you are not lacking in any spiritual gift as
you wait for the revealing of our Lord jesus Christ. BHe will also
strengthen you to the end, so that you may be blameless on the
day of our Lord jesus Christ. 9God is faithful; by him you were
called into the fellowship of his Son, jesus Christ our Lord.
a Gk theirs b Other anci ent authorities lack my c Or to
39
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
2 CORINTHIANS 1
Greek New Testament
TIPOl: KOPIN8JOY2: B
1
TiauAos- cirrooToAos- XpwTou ' lfloou ou:l 6EOu
KQl TL!l06EOS' 6 aOEAcpOS' Tfl EKKAT]OLQ- TOU 6EoiJ TD OUOlJ
EV Kop[v6tp avv TotS ayLOLS' TnlOLV TOLS' OUOLV EV OAlJ TD
'Axatr;r., 2 xcipLS' u111v Kal. cnro 6Eou rraTpos-
KaL Kuplou 'IT]ooiJ XpwTou.
3 EuAoyT]Tos- 6 eEos- Kat Tou Kup[ou 'ITJaou
XpwTou, 6 Twv oLKTLpjlWV KUL 6EOS' rrciOT]S'
OEWS' , 4 6 rrapaKaAwv E'rrl. rrciolJ TD 6A[lj;EL Els-
TO 8uvao6m rrapaKaAELV TOUS' E'v rrciolJ 6A.tlj;EL 8La
TTtS' rrapaKaAOUjlE6a auTo!. urro ToiJ 6Eou.
5 on Ka6ws- rrEpLOOEUEL Ta ToiJ XpwTou Eis-
OliTWS' OLa TOiJ XpLOTOU rrEpLOOEUEL Kal. rrapciKATJOLS'
6 dTE OE urrE:p TftS' UjlWV
KQL OWTT]p[as- ElTE rrapaKQAOUj1E6a , urrE:p TllS' UjlWll
TllS' EVEpyoujlEVTJS' EV urrojlovfj TWV auTwv
rra6T]jlciTwv wv Kal. rrcioxollEv. 7 Kal. E'A. rrl.s-
urrEp UjlWV ElBOTES' on KOLvwvo[ EOTE Twv rra6T]-
jlciTwv, oihws- Kal. TllS' rrapaKArJOHuS'.
Amplified Bible
THE SECOND LETTER OF PAUL TO THE
CORINTHIANS
1
PAUL, AN apostle (a special messenger) of Christ jesus by the
will of God, and Timothy [our] brother, to the church (assem-
bly) of God which is at Corinth, and to all the saints (the people
of God) throughout Achaia (most of Greece):
2 Grace (favor and spiritual blessing) to you and [heart) peace
from God our Father and the Lord Jesus Christ (the Messiah, the
Anointed One).
3 Blessed be the God and Father of our Lord jesus Christ, the
Father of sympathy (pity and mercy) and the God [Who is the
Source) of every comfort (consolation and encouragement),
4 Who comforts (consoles and encourages) us in every trouble
(calamity and affliction), so that we may also be able to comfort
(console and encourage) those who are in any kind of trouble or
distress, with the comfort (consolation and encouragement) with
which we ourselves are comforted (consoled and encouraged) by
God.
5 For just as Christ's (aown) sufferings fall to our lot b[as they
overflow upon His disciples, and we share and experience them]
abundantly, so through Christ comfort (consolation and encour-
agement) is also (shared and experienced] abundantly by us.
6 But if we are troubled (afflicted and distressed), it is for your
comfort (consolation and encouragement) and [for your) salva-
tion; and if we are comforted (consoled and encouraged), it is for
your comfort (consolation and encouragement), which works [in
you) when you patiently endure the same evils (misfortunes and
calamities) that we also suffer and undergo.
7 And our hope for you [our joyful and confident expectation
of good for you) is ever unwavering (assured and unshaken); for
we know that just as you share and are partners in (our) suffer-
ings and calamities, you also share and are partners in [our]
comfort (consolation and encouragement).
954
King James Version
THE SECOND EPISTLE OF ST. PAUL TO THE
CORINTHIANS
1
Paul , an apostle of Jesus Christ by the will of God, and
Timothy our brother, unto the church of God which is at
Corinth, with all the saints which are in all Achaia:
2 Grace be to you and peace from God our Father, andftom
the Lord Jesus Christ.
3 Blessed be God, even the Father of our Lord jesus Christ,
the Father of mercies, and the God of all comfort;
4 Who comforteth us in all our tribulation, that we may be
able to comfort them which are in any trouble, by the comfort
wherewith we ourselves are comforted of God.
5 For as the sufferings of Christ abound in us, so our consola-
tion also aboundeth by Christ.
6 And whether we be afflicted, it is for your consolation and
salvation, which is effectual in the enduring of the same suffer-
ings which we also suffer: or whether we be comforted, it is for
your consolation and salvation.
7 our hope of you is stedfast, knowing, that as ye are
partakers of the sufferings, so shallye be also of the consolation.
Rheims New Testament
THE SECOND EPISTLE OF ST. PAUL TO THE
CORINTHIANS
1
Paul, an apostle of jesus Christ by the will of God, and
Timothy our brother: to the church of God that is at Corinth,
with all the saints that are in all Achaia:
2 Grace unto you and peace from God our Father, and from
the Lord Jesus Christ.
3 Blessed be the God and Father of our Lord jesus Christ, the
Father of mercies, and the God of all comfort.
4 Who comforteth us in all our tribulation; that we also may
be able to comfort them who are in all distress, by the exhorta-
tion wherewith we also are exhorted by God.
5 For as the sufferings of Christ abound in us: so also by
Christ doth our comfort abound.
6 Now whether we be in tribulation, it is for your exhortation
and salvation: or whether we be comforted, it is for your consola-
tion: or whether we be exhorted, it is for your exhortation and
salvation, which worketh the enduring of the same sufferings
which we also suffer.
7 That our hope for you may be steadfast: knowing that as
you are partakers of the sufferings, so shall you be also of the
consolation.
AB: a Marvin Vincent, Word Studies in the New Testamem. b Marvin
Vincent, Word Studies.
40
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
955
New American Standard Bible
THE SECOND EPISTLE OF PAUL TO THE
CORINTHIANS
1
Paul, an apostle of Christ jesus by the will of God, and
Timothy our brother, to the church of God which is at Corinth
with all the saints who are throughout Achaia:
2 Grace to you and peace from God our Father and the Lord
jesus Christ.
3 Blessed be the God and Father of our Lord jesus Christ, the
Father of mercies and God of all comfort;
4 who comforts us in all our affliction so that we may be able
to comfort those who are in any affliction with the comfort with
which we ourselves are comforted by God.
5 For just as the sufferings of Christ are ours in abundance, so
also our comfort is abundant through Christ.
6 But if we are afflicted, it is for your comfort and salvation; or
if we are comforted, it is for your comfort, which is effective in
the patient enduring of the same sufferings which we also suffer;
7 and our hope for you is firmly grounded, knowing that as
you are sharers of our sufferings, so also you are sharers of our
comfort .
New American Bible
THE SECOND LETTER TO THE
CORINTHIANS
1
Paul, an apostle of Christ jesus by the will of God, and
Timothy our brother, to the church of God that is in Corinth,
with all the holy ones throughout Achaia: zgrace to you and
peace from God our Father and the Lord jesus Christ.
3BJessed be the God and Father of our Lord jesus Christ, the
Father of compassion and God of all encouragement,
4
who
encourages us in our every affliction, so that we may be able to
encourage those who are in any affliction with the encouragement
with which we ourselves are encouraged by God. SFor as Christ's
sufferings overflow to us, so through Christ does our encourage-
ment also overflow. 61f we are afflicted, it is for your en-
couragement and salvation; if we are encouraged, it is for your
encouragement, which enables you to endure the same sufferings
that we suffer. 7Qur hope for you is firm, for we know that as you
share in the sufferings, you also share in the encouragement.
2 CORINTHIANS 1
New International Version
2 CORINTHIANS
1
Paul, an apostle of Christ jesus by the will of God, and
Timothy our brother,
To the church of God in Corinth, together with all the saints
throughout Achaia:
2Grace and peace to you from God our Father and the Lord
jesus Christ.
3Praise be to the God and Father of our Lord jesus Christ, the
Father of compassion and the God of all comfort, 4who comforts
us in all our troubles , so that we can comfort those in any trouble
with the comfort we ourselves have received from God. SFor just
as the sufferings of Christ flow over into our lives, so also
through Christ our comfort overflows. 6Jf we are distressed, it is
for your comfort and salvation; if we are comforted, it is for your
comfort, which produces in you patient endurance of the same
sufferings we suffer. 7And our hope for you is firm, because we
know that just as you share in our sufferings, so also you share
in our comfort.
New Revised Standard Version
THE SECOND LETTER OF PAUL TO THE
CORINTHIANS
1
Paul, an apostle of Christ jesus by the will of God, and
Timothy our brother,
To the church of God that is in Corinth, including all the saints
throughout Achaia:
2 Grace to you and peace from God our Father and the Lord
jesus Christ.
3 Blessed be the God and Father of our Lord jesus Christ, the
Father of mercies and the God of all consolation, 4who consoles
us in all our affliction, so that we may be able to console those
who are in any affliction with the consolation with which we
ourselves are consoled by God. Sfor just as the sufferings of
Christ are abundant for us, so also our consolation is abundant
through Christ. 6Jf we are being afflicted, it is for your consola-
tion and salvation; if we are being consoled, it is for your conso-
lation, which you experience when you patiently endure the same
sufferings that we are also suffering. 7Qur hope for you is
unshaken; for we know that as you share in our sufferings, so
also you share in our consolation.
41
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
GALATIANS 1
Greek New Testament
TIPOL: r AAA TAL:
1
ITauA.os cim:laTOAOS' OUK an' av8pwnwv ov8i.= 8L > av8pwnou
ciA.A.cl 8u1 'lrpou XpwTou Kal 8Eou naTpos Tou E:ydpav-
TOS' QVTOV EK VEKpwv, 2 Kal o'L avv EllOL nciVTES' a8EAot
TULS' EKKAT]GLaLS' faAaT[as, 3 xcipLS' VllLV Kal
uno 8wu naTpos Kat KUpl ou 'lT]aou XpwTou 4 Tov
86vTos EauTov uni=p Twv O.J..wpnwv cmws
E:K Tau atwvos Tau E:vwTwTos novTJpou KaTa To eE:-
A.wa Tou 8Eov Kat naTpos 5 c;J ELs Taus
alwvas Twv alwvwv,
6 eaullci(w OTL OlJTWS' TUXEWS' J.l.ETGTL8Ea8E cino TOU KU-
AEGUVTOS' Uj.l.iiS' EV xcipLTL [XpwTOU] ELS' ETEpov EuayyEALOV,
7 0 OUK EGTLV aAA.o, El TLVES' ELGLV ol. TapciaaOVTES'
VJ.Los Kat 8E:A.ovTES' llETaaTpb)!m To EuayyEALOv Tou
XpLaTOU. 8 ana KUL E:av ayyEAOS' oupavov
EuayyEAL(TJTaL [uj.l.Lv] nap' o EUTJYYEAwci!lE8a u11'Lv, civci8Eila
EGTW. 9 WS' KUL apn nciALV AEyw, d TLS"
VJ.LiiS' EuayyEAL(ETm nap' o civci8Eila EaTw.
Amplified Bible
THE LETTER OF PAUL TO THE
GALATIANS
1
PAUL, AN apostle-[special messenger appointed and com-
missioned and sent out] not from [any body of) men nor by or
through aany man, but by and through Jesus Christ (the Messiah)
and God the Father, Who raised Him from among the dead-
2 And all the brethren who are with me, to the churches of
Galatia:
3 Grace and spiritual blessing be to you and (soul] peace from
God the Father and our Lord Jesus Christ (the Messiah),
4 Who gave (yielded) Himself tip [bto atone] for our sins (and
ct:o save and sanctify us], in order to rescue and deliver us from
this present wicked age and world order, in accordance with the
will and purpose and plan of our God and Father-
S To Him [be ascribed all] the glory through all the ages of the
ages and the eternities of the eternities! Amen (so be it).
6 I am surprised and astonished that you are so quickly dturn-
ing renegade and deserting Him Who invited and called you eby
the grace (unmerited favor) of Christ (the Messiah) (and that you
are transferring your allegiance] to a different (even an opposi-
tion] gospel.
7 Not that there is (or could be] any other (genuine Gospel], but
there are (obviously] some who are troubling and disturbing and
bewildering you [lwith a different kind of teaching which they
offer as a gospel] and want to pervert and distort the Gospel of
Christ (the Messiah) [into something which it absolutely is not] .
8 But even if we or an angel from heaven should preach to
you a gospel contrary to and different from that which we
preached to you, let him be accursed (anathema, devoted to
destruction, doomed to eternal punishment)!
9 As we said before, so I now say again: If anyone is preach-
ing to you a gospel different from or contrary to that which you
received [from us], let him be accursed (anathema, devoted to
destruction, doomed to eternal punishment)!
1006
King James Version
THE EPISTLE OF ST. PAUL TO THE
GALATIANS
1
Paul, an apostle, (not of men, neither by man, but by Jesus
Christ, and God the Father, who raised him from the dead;)
2 And all the brethren which are with me, unto the churches
of Galatia:
3 Grace be to you and peace from God the Father, andfiom
our Lord Jesus Christ,
4 Who gave himself for our sins, that he might deliver us from
this present evil world, according to the will of God and our
Father:
5 To whom be glory for ever and ever. Amen.
6 I marvel that ye are so soon removed from him that called
you into the grace of Christ unto another gospel:
7 Which is not another; but there be some that trouble you,
and would pervert the gospel of Christ.
8 But though we, or an angel from heaven, preach any other
gospel unto you than that which we have preached unto you, let
him be accursed.
9 As we said before, so say I now again, If any man preach
any other gospel unto you than that ye have received, let him be
accursed.
Rheims New Testament
THE EPISTLE OF ST. PAUL TO THE
GALATIANS
1
Paul, an apostle, not of men, neither by man, but by Jesus
Christ, and God the Father, who raised him from the dead,
1
2 And all the brethren who are with me, to the churches of
Galatia.
3 Grace be to you, and peace from God the Father, and from
our Lord Jesus Christ, 1
4 Who gave himself for our sins, that he might deliver us from
this presem wicked world, according to the will of God and otir
Father:
5 To whom is glory for ever and ever. Amen.
6 I wonder that you are so soon removed from him that called
you into the grace of Christ, unto another gospel.
7 Which is not another, only there are some that trouble you,
and would pervert the gospel of Christ.
8 But though we, or an angel from heaven, preach a gospel to
you besides that which we have preached to you, let him be
anathema.
9 As we said before, so now I say again: If any one preach to
you a gospel, besides that which you have received, let him be
anathema.
AB: a Marvin Vincent, Word Stlldies in the New Tescament. b Marvin
Vincent, Word Studies in the New Testament . c Marvin Vincent, Word
Studies in the New Testament. d joseph P. Lightfoot , Notes on the Epistles
q/Saint Paul. e Marvin Vincent, Word Studies in the New Testament.
J Marvin Vincent, Word Studies in the New Testament.
42
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
1007
New American Standard Bible
THE EPISTLE OF PAUL TO THE
GALATIANS
1
Paul, an apostle (not sent from men, nor through the agency
of man. bur through jesus Christ, and God the Father, who
raised Him from the dead) ,
2 and all the brethren who are with me, to the churches of
Galatia:
3 Grace to you and peace from God our Father. and the Lord
jesus Christ,
4 who gave Himself for our sins, that He might deliver us out
of this present evil age, according to the will of our God and
Father,
5 to whom be the glory forevermore. Amen.
6 I am amazed that you are so quickly deserting Him who
called you by the grace of Christ. for a different gospel;
7 which is really not another; only there are some who are dis-
turbing you, and want to distort the gospel of Christ.
8 But even though we, or an angel from heaven. should preach
to you a gospel contrary to that which we have preached to you.
let him be accursed.
9 As we have said before, so I say again now, if any man is
preaching to you a gospel contrary to that which you received, let
him be accursed.
New American Bible
THE LETTER TO THE
GALATIANS
1
Paul, an apostle not from human beings nor through a
human being but through jesus Christ and God the Father
who raised him from the dead, 2and all the brothers who are
,with me, to the churches of Galatia: 3grace to you and peace
from God our Father and the Lord jesus Christ, 4who gave him-
self for our sins that he might rescue us from the present evil age
in accord with the will of our God and Father, 5to whom be glory
forever and ever. Amen.
6I am amazed that you are so quickly forsaking the one who
called you by [the] grace [of Christ] for a different gospel 7(not
that there is another). But there are some who are disturbing you
and wish to pervert the gospel of Christ. BBut even if we or an
angel from heaven should preach [to you] a gospel other than the
one that we preached to you, let that one be accursed! 9As we
have said before, and now I say again, if anyone preaches to you
a gospel other than the one that you received, let that one be
accursed!
GALATIANS 1
New International Version
GALATIANS
1
Paul, an apostle-sent not from men nor by man. but by
jesus Christ and God the father. who raised him from the
dead- 2and all the brothers with me.
To the churches in Galatia:
3Grace and peace to you from God our Father and the Lord
jesus Christ, 4who gave himself for our sins to rescue us from
the present evil age, according to the will of our God and Father.
Sto whom be glory for ever and ever. Amen.
6I am astonished that you are so quickly deserting the one who
called you by the grace of Christ and are turning to a different
gospel- 7which is really no gospel at alL Evidently some people
are throwing you into confusion and are trying to pervert the
gospel of Christ. BBut even if we or an angel from heaven should
preach a gospel other than the one we preached to you, let him
be eternally condemned! 9As we have already said, so now I say
again: If anybody is preaching to you a gospel other than what
you accepted. let him be eternally condemned!
New Revised Standard Version
THE LETTER OF PAUL TO THE
GALATIANS
1
Paul an apostle-sent neither by human commission nor
from human authorities, but through jesus Christ and God
the Father, who raised him from the dead- 2and all the mem-
bers of God's famiJya who are with me,
To the churches of Galatia:
3 Grace to you and peace from God our Father and the Lord
jesus Christ. 4who gave himself for our sins to set us free from
the present evil age, according to the will of our God and Father.
5to whom be the glory forever and ever. Amen.
6 I am that you are so quickly deserting the one
who called you in the grace of Christ and are turning to a differ-
ent gospel- 7not that there is another gospel, but there are
some who are confusing you and want to pervert the gospel of
Christ. BBut even if we or an angelb from heaven should proclaim
to you a gospel contrary to what we proclaimed to you, let that
one be accursed! 9As we have said before, so now I repeat. if
anyone proclaims to you a gospel contrary to what you received,
let that one be accursed!
a Gk all the brothers b Or a messenger
43
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
EPHESIANS 1
Greek New Testament
TTPOL:; E<PEL:;IOYL:
1
TiauA.os- cino<noA.os- 'IT]aou 8u1 8Eou
TolS" ayLOLS" TOtS ovaLV [Ev 'E<jlEG<;J] KQL TILCJTOLS" EV
XpwT<i] 'IT]aou, 2 xcipLs- UflLV Kai cino 8Eou naTpos-
Ka'L Kup[ou 'IT]aOu XpwTou.
3 EuA.oyT]Tos- 6 8Eos Kal Tou KUptou 'IT]aou
XpwTou, 6 EuA.oyijaas EV ncial] EuA.oy[q. nvEuflaTLKi]
EV Tots Enoupav[oLs Ev XpwT<jj, 4 Ka8ws
EV auT<jj npo KOG!lOU Elvm ay[ous Kal
clflWflOUS" KUTEVWTILOV auTOU EV ciycinl] , 5 npoop[aas
ELS UL08Eaf.av OL<l 'IT]GOU XpLCJTOU ELS auTOV, KQTQ
EVOOKLaV TOU 8EArlflUTOS auTOU, 6 ELS ETiaLVOV TiiS
xcipLTOS auTOU ExapLTWGEV EV T<jj ijyaTIT]flEV4J.
7 EV 4i EXOflEV cinoA.uTpwmv OLa TOU a'[flaTOS at.JTOU,
a<jlEaLV TWV napaTITWflclTWV, KGTU TO TIAOUTOS TllS xci-
plTOS auTOU 8 ETIEpf.aaEUGEV ELS EV ncial] ao<jl[q.
Kal povijaEL, 9 yvwp[aas To flUaTijpLov TOU 8EAr'jf1.a-
TOS Ql.JTOU, KaTa EUOOKLQV mJTOU npoE8ETO EV auT<jj
Amplified Bible
THE LETTER OF PAUL TO THE
EPHESIANS
1
PAUL, AN apostle (special messenger) of Christ jesus (the
Messiah), by the divine will (the purpose and the choice of
God) to the saints (the consecrated, set-apart ones) aat Ephesus
who are also faithful and loyal and steadfast in Christ jesus:
2 May grace (God's unmerited favor) and spiritual peace [which
means peace with God and harmony, unity, and undisturbedness)
be yours from God our Father and from the Lord jesus Christ.
3 May blessing (praise, laudation, and eulogy) be to the God
and Father of our Lord jesus Christ (the Messiah) Who has
blessed us in Christ with every spiritual (given by the Holy Spirit)
blessing in the heavenly realm!
4 Even as [in His love) He chose us [actually picked us out for
Himself as His own) in Christ before the foundation of the world,
that we should be holy (consecrated and set apart for Him) and
blameless in His sight, even above reproach, before Him in love.
5 For He foreordained us (destined us, planned in love for us)
to be adopted (revealed) as His own children through jesus
Christ, in accordance with the purpose of His will [bbecause it
pleased Him and was His kind intent]-
6 [So that we might be] to the praise and the commendation
of His glorious grace (favor and mercy), which He so freely
bestowed on us in the Beloved.
7 In Him we have redemption (deliverance and salvation)
through His blood, the remission (forgiveness) of our offenses
(shortcomings and trespasses), in accordance with the riches and
the generosity of His gracious favor,
8 Which He lavished upon us in every kind of wisdom and
understanding (practical insight and prudence),
9 Making known to us the mystery (secret) of His will (of His
plan, of His purpose). [And it is this:) In accordance with His
good pleasure (His merciful intention) which He had previously
purposed and set forth in cHim,
1036
King James Version
THE EPISTLE OF ST. PAUL TO THE
EPHESIANS
1
Paul , an apostle of jesus Christ by the will of God, to the
saints which are at Ephesus, and to the faithful in Christ
jesus:
2 Grace be to you, and peace, from God our Father, andftom
the Lord jesus Christ.
3 Blessed be the God and Father of our Lord jesus Christ,
who hath blessed us with all spiritual blessings in heavenly
places in Christ:
4 According as he hath chosen us in him before the founda-
tion of the world, that we should be holy and without blame
before him in love:
5 Having predestinated us unto the adoption of children by
jesus Christ to himself, according to the good pleasure of his will,
6 To the praise of the glory of his grace, wherein he hath
made us accepted in the beloved.
7 In whom we have redemption through his blood, the for-
giveness of sins, according to the riches of his grace;
8 Wherein he hath abounded toward us in all wisdom and
prudence;
9 Having made known unto us the mystery of his will, accord-
ing to his good pleasure which he hath purposed in himself:
Rheims New Testament
THE EPISTLE OF ST. PAUL TO THE
EPHESIANS
1
Paul, an apostle of jesus Christ, by the will of God, to all the
saints who are at Ephesus, and to the faithful in Christ jesus.
2 Grace be to you, and peace from God the Father, and from
the Lord jesus Christ.
3 Blessed be the God and Father of our Lord jesus Christ, who
hath blessed us with spiritual blessings in heavenly places, in
Christ:
4 As he chose us in him before the foundation of the world,
that we should be holy and unspotted in his sight in charity.
5 Who hath predestinated us unto the adoption of children
through jesus Christ unto himself: according to the purpose of his
will :
6 Unto the praise of the glory of his grace, in which he hath
graced us in his beloved son.
7 In whom we have redemption through his blood, the remis-
sion of sins, according to the riches of his grace,
8 Which hath superabounded in us in all wisdom and pru-
dence,
9 That he might make known unto us the mystery of his will,
according to his good pleasure, which he hath purposed in him,
AB: a Some manuscripts do not contain "at Ephesus. b Marvin Vincent.
Word Studies in the New Testament. c Some commentators interpret "in
Him" to mean "in Himself, "while others see it as "in Christ."
44
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
1037
New American Standard Bible
THE EPISTLE OF PAUL TO THE
EPHESIANS
1
Paul, an apostle of Christ jesus by the will of God, to the
saints who are tat Ephesus, and who are faithful in Christ
Jesus:
2 Grace to you and peace from God our Father and the Lord
Jesus Christ.
3 Blessed be the God and Father of our Lord jesus Christ, who
has blessed us with every spiritual blessing in the heavenly
places in Christ,
4 just as He chose us in Him before the foundation of the
world, that we should be holy and blameless before 2!-lim. In love
5 He predestined us to adoption as sons through jesus Christ
to Himself, according to the kind intention of His will,
6 to the praise of the glory of His grace, which He freely
bestowed on us in the Beloved.
7 In Him we have redemption through His blood, the forgive-
ness of our trespasses, according to the riches of His grace,
8 which He lavished upon us. In all wisdom and insight
9 He made known to us the mystery of His will, according to
His kind intention which He purposed in Him
Some ancient mss. do not contain at Ephesus 2 Or, Him, in love.
New American Bible
THE LETTER TO THE
EPHESIANS
1
Paul, an apostle of Christ jesus by the will of God, to the holy
ones who are [in Ephesus] faithful in Christ jesus: 2grace to
you and peace from God our Father and the Lord jesus Christ.
, 3Blessed be the God and Father of our Lord jesus Christ, who
has blessed us in Christ with every spiritual blessing in the heav-
ens, 4as he chose us in him, before the foundation of the world,
to be holy and without blemish before him. In love She destined
us for adoption to himself through jesus Christ, in accord with
the favor of his will, 6for the praise of the glory of his grace that
he granted us in the beloved.
7In him we have redemption by his blood, the forgiveness of
transgressions, in accord with the riches of his grace Bthat he
lavished upon us . In all wisdom and insight, 9he has made
known to us the mystery of his will in accord with his favor that
1, 1: [In Ephesus]: the phrase is lacking in important early witnesses such
as P46 (3rd cent.), and Sinaiticus and Vaticanus (4th cent.), appearing in the
latter two as a fifth-century addition. Basil and Origen mention its absence
from manuscripts.
EPHESIANS 1
New International Version
EPHESIANS
1 Paul, an apostle of Christ jesus by the will of God,
To the saints in Ephesus, a the faithfulb in Christ Jesus:
2Grace and peace to you from God our Father and the Lord
jesus Christ.
3Praise be to the God and Father of our Lord jesus Christ, who
has blessed us in the heavenly realms with every spiritual bless-
ing in Christ. 4For he chose us in him before the creation of the
world to be holy and blameless in his sight. In love Shec predes-
tined us to be adopted as his sons through jesus Christ, in accor-
dance with his pleasure and will- 6to the praise of his glorious
grace, which he has freely given us in the One he loves. 7In him
we have redemption through his blood, the forgiveness of sins, in
accordance with the riches of God's grace Bthat he lavished on us
with all wisdom and understanding. 9And hed made known to us
the mystery of his will according to his good pleasure, which he
a 1 Some early manuscripts do not have in Ephesus. b 1 Or believers who
are c 4,5 Or sight in love. SHe d 8,9 Or us. With all wisdom and under-
standing, 9he
New Revised Standard Version
THE LETTER OF PAUL TO THE
EPHESIANS
1
Paul, an apostle of Christ jesus by the will of God,
To the saints who are in Ephesus and are faithfuJa in Christ
jesus:
2 Grace to you and peace from God our Father and the Lord
jesus Christ.
3 Blessed be the God and Father of our Lord jesus Christ, who
has blessed us in Christ with every spiritual blessing in the heav-
enly places, 4just as he chose us in Christb before the foundation
of the world to be holy and blameless before him in love. SHe
destined us for adoption as his children through jesus Christ,
according to the good pleasure of his will, 6to the praise of his
glorious grace that he freely bestowed on us in the Beloved. 7In
him we have redemption through his blood, the forgiveness of
our trespasses, according to the riches of his grace Bthat he lav-
ished on us. With all wisdom and insight 9he has made known
to us the mystery of his will, according to his good pleasure that
a Other ancient authorities lack in Ephesus, reading saints who are also
Jaitlful b Gk in him
45
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
PHILIPPIANS 1
Greek New Testament
TTPO:L: <PIAITTTIH:L:IOY:L:
1
ITauA.os- Kal TLf1-08EOS' oouA.m XpLoTou 'l11aou rriimv TOLS'
ayLOLS' EV XpwTtiJ 'lllO"OU TolS' OlJO"LV EV LAL TrTrOLS' avv
EmaKorrms- Kal owKovms-, 2 xcipLS' ufJ.'lv Kal cirro
8Eou rraTpos- wl Kup[ou 'l11aou XpwTou.
3 Euxapwn0 8E0 fl.OU Errl rrcial] TTJ jlVEL<;L u11wv
4 rrciVTOTE EV rrcial] jlOU urrEp rrcivTwv VjlWV, jlETa
xapiis- OEllO"LV TrOLOUjlEVOS'' 5 ETrL TTJ KOLVlLJVL<;L UjlWV
ELS' TO EUayyEALOV cirro nlS' rrpWTllS' axpl TOU vvv,
6 TrETrOL8WS' auTO TOUTO, ClTL 6 EVap(cifJ.EVOS' EV Ufl.LV Epyov
ciya8ov ETrLTEAE<JEL axpl XpwTOU 'lllO"OU' 7 Ka8WS'
EO"TLV OLKaLOV EjlOL TOUTO poVELV UTrEp rraVTWV Vfl.WV OLa
To EXELV w Ev TTJ wpo[q ufJ.os, Ev TE To'Ls- ow
11
o'Ls- 11ou
Kal Ev TTJ cirroA.oy[q_ Kal Tou EuayyEA.[ou auyKm-
vwvous- fl.OU Tf]S' xcipLTOS' rrcivTGS' Ujl(JS OVTGS'. 8 jlclpTUS'
ycip 11ou 6 8EOS' ws- Emrro8w rrcivms- ujliiS' Ev arrAciyxvms-
XpwTou 'l11aou. 9 Kal TOUTO rrpoaEuxo11m, 'Lva ciycirr11
Vfl.WV En wrAA.ov Kal fJ.iiAAov TIE pwaEUT] EV Em yvu)aEL Kal
Amplified Bible
THE LEITER OF PAUL TO THE
PHILIPPIANS
1
PAUL AND Timothy, bond servants of Christ jesus (the
Messiah), to all the saints (God's consecrated people) in
Christ Jesus who are at Philippi, with the bishops (overseers) and
deacons (assistants):
2 Grace (favor and blessing) to you and [heart] peace from
God our Father and the Lord Jesus Christ (the Messiah) .
3 l thank my God in all my remembrance of you.
4 In every prayer of mine l always make my entreaty and peti-
tion for you all with joy (delight).
5 [I thank my God] for your fellowship (your asympathetic
cooperation and contributions and partnership) in advancing the
good news (the Gospel) from the first day [You heard it] until
now.
6 And l am convinced and sure of this very thing, that He
Who began a good work in you will continue until the day of
jesus Christ [right up to the time of His return], developing [that
good work] and perfecting and bringing it to full completion in
you.
7 It is right and appropriate for me to have this confidence
and feel this way about you all, because byou have me in your
heart and I hold you in my heart as partakers and sharers, one
and all with me, of grace (God's unmerited favor and spiritual
blessing). [This is true] both when l am shut up in prison and
when I am out in the defense and confirmation of the good news
(the Gospel).
8 For God is my witness how I long for and cpursue you all
with love, in the tender mercy of Christ jesus [Himsein!
9 And this I pray: that your love may abound yet more and
more and extend to its fullest development in knowledge and all
keen insight [that your love may ddisplay itself in greater depth of
acquaintance and more comprehensive discernment],
1066
King James Version
THE EPISTLE OF ST. PAUL TO THE
PHILIPPIANS
1
Paul and Timotheus, the servants of jesus Christ, to all the
saints in Christ jesus which are at Philippi, with the bishops
and deacons:
2 Grace be unto you, and peace, from God our Father; and
.from the Lord jesus Christ.
3 l thank my God upon every remembrance of you,
4 Always in every prayer of mine for you all making request
with joy,
5 For your fellowship in the gospel from the first day until
now;
6 Being confident of this very thing, that he which hath begun
a good work in you will perform it until the day of jesus Christ:
7 Even as it is meet for me to think this of you all, because I
have you in my heart; inasmuch as both in my bonds, and in the
defence and confirmation of the gospel, ye all are partakers of my
grace.
8 For God is my record, how greatly l long after you all in the
bowels of jesus Christ.
9 And this l pray, that your love may abound yet more and
more in knowledge and in all judgment;
Rheims New Testament
THE EPISTLE OF ST. PAUL TO THE
PHILIPPIANS
1
Paul and Timothy, the servants of jesus Christ; to all the
saints in Christ jesus, who are at Philippi, with the bishops
and deacons.
2 Grace be unto you, and peace from God our Father, and from
the Lord Jesus Christ. . .
3 l give thanks to my God in every remembrance of you,
4 Always in all my prayers making supplication for you all,
with joy;
5 For your communication in the gospel of Christ from the
first day until now.
6 Being confident of this very thing, that he, who hath begun
a good work in you, will perfect it unto the day of Christ jesus.
7 As it is meet for me to think this for you all, for that I have
you in my heart; and that in my bands, and in the defence and
confirmation of the gospel, you all are partakers of my joy.
8 For God is my witness, how I long after you all in the bowels
of jesus Christ.
9 And this l pray, that your charity may more and more
abound in knowledge, and in all understanding:
AB: a Marvin Vincent, Word Studies in the New Testament. b Alternate
translation. c joseph Thayer, A Greek-English Lexicon ef the New
Testament. d Marvin Vincent, Word Studies in the New Testament.
46
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
New Ame rican Standa rd Bible
THE EPISTLE OF PAUL TO THE
PHILIPPIANS
Paul and Timothy, bond-servants of Christ jesus, to all the
saints in Christ jesus who are in Philippi , including the over-
s ers and deacons:
2 Grace to you and peace from God our Father and the Lord
.sus Christ.
:; I thank my God in all my remembrance of you,
4 always offering prayer with joy in my every prayer for you
.
5 in view of your participation in the gospel from the first day
until now.
{, For I am confident of this very thing, that He who began a
good work in you will perfect it until the day of Christ jesus.
z For it is only right for me to feel this way about you all,
ecause I have you in my heart, since both in my imprisonment
nd in the defense and confirmation of the gospel, you all are
artakers of grace with me.
s For God is my witness, how I long for you all with the affec-
tion of Christ jesus.
9 And this I pray, that your love may abound still more and
more in real knowledge and all discernment,
New American Bible
THE LETTER TO THE
PHILIPPIANS
Paul and Timothy, slaves of Christ jesus, to all the holy ones
in Christ jesus who are in Philippi, with the overseers and
ministers: 2grace to you and peace from God our Father and the
l!.ord jesus Christ.
'"31 give thanks to my God at every remembrance of you, 4pray-
ing.always with joy in my every prayer for all of you, Sbecause of
.our partnership for the gospel from the first day until now. 6]
am confident of this, that the one who began a good work in you
will continue to complete it until the day of Christ jesus. 7It is
ri&,ht that I should think this way about all of you, because I hold
pu in my heart, you who are all partners with me in grace, both
m my imprisonment and in the defense and confirmation of the
g0spel. BFor God is my witness, how !long for all of you with the
affection of Christ jesus. 9And this is my prayer: that your love
may increase ever more and more in knowledge and every kind of
P HILIPPIANS 1
New International Version
PHILIPPIANS
1 Paul and Timothy, servants of Christ jesus ,
To all the saints in Christ jesus at Philippi, together with the
overseersa and deacons:
2Grace and peace to you from God our Father and the Lord
jesus Christ.
3] thank my God every time 1 remember you. 41n all my prayers
for all of you, I always pray with joy sbecause of your partner-
ship in the gospel from the first day until now, 6being confident
of this, that he who began a good work in you will carry it on to
completion until the day of Christ jesus.
7Jt is right for me to feel this way about all of you, since I have
you in my heart; for whether I am in chains or defending and
confirming the gospel, all of you share in God's grace with me.
BGod can testify how I long for all of you with the affection of
Christ jesus.
9And this is my prayer: that your love may abound more and
more in knowledge and depth of insight, wso that you may be
a 1 Traditionally bishops
New Revised Standard Version
THE LETTER OF PAUL TO THE
PHILIPPIANS
1
Paul and Timothy, servantsa of Christ jesus,
To all the saints in Christ jesus who are in Philippi , with the
bishopsb and deacons:c
2 Grace to you and peace from God our Father and the Lord
jesus Christ
3 I thank my God every time I remember you, 4constantly
praying with joy in every one of my prayers for all of you,
Sbecause of your sharing in the gospel from the first day until
now. 6J am confident of this, that the one who began a good
work among you will bring it to completion by the day of jesus
Christ. _7Jt is right for me to think this way about all of you,
because you hold me in your heart,d for all of you share in God's
gracee with me, both in my imprisonment and in the defense and
confirmation of the gospeL BFor God is my witness, how I long
for all of you with the compassion of Christ jesus. 9And this is
my prayer, that your love may overflow more and more with
a Gk slaves b Or overseers c Or overseers and helpers d Or because I
hold you in my heart e Gk in grace
47
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
COLOSSIANS 1
Greek New Testament
TIPOL: KOAOL:l::AEil::
1
nau)..os anciaToAos XpwTou 'lrwou 8La 9EATUJ.aTos 9Eou
KaL Tq.J.69EOS' 6 a8EA.cpos 2 nils EV KoAoaaals Q_')'LOLS'
KGL 1TLGTOLS' a8EA0LS' EV XpwT4), xcipLS' Ul.l.LV Kal
am) 9EOU naTpOS'
3 EuxapLGTOUiJ.EV T4) 9E0 naTpl TOU KUpLOU 'IT]GOU
XpwTou ncivTOTE nEpl Ul.l.WV npoaEUXOI.l.EVOL, 4 aKm)aav-
TES' TTJV 1TLGTLV Ul.l.WV EV XpwT0 'IT]GOU KGL TTJV ayriTIT]V flv
EXETE ElS' ncivms TOUS' ayi.ous 5 8L<1 TTJV EATIL8a TTJV ano-
KELI.l.EVT]V Ui.J.LV EV TolS' oupavo'ls, flv npOT]KOlJGGTE EV T4)
A.6y4J aA.r]9das TOU EuayyEALou 6 Tou napcivTOS' Eis
ul.liiS', Ka9ws Kal. v navTl T0 KOGI.l.Lfl aT\. v Kapnocpopou-
11-Evov Kal Ka9ws Kal EV UJ..llV, a'
Kal ETIEYVWTE TTJV xcipLV TOU 9EOU EV UAT]9Ei.q..
7 Ka9ws EJ..lcl9ETE ana 'Enapii TOU ayanT]TOU auv8ouA.ou
OS' EGTLV 1TLGTOS' UTIEp UJ..l.WV OLclKOVOS' TOU XpLGTOU,
8 6 Kal 8T]A.waas TTJV UJ..l<;-JV ciycinT]V EV TIVEUJ..l.UTL.
9 t.La TOUTO KaL a' OU
rraUOJ..lE9a unE:p UJ..l.WV npoaEUXOJ..lEVOL KGL al TOUJ..l.EVOL, 'va
TTJV ni.yvwaw Tou atJTOU v ncialJ
aocpi.q. KGL GUVEGEL 1TVEUJ..l.UTLKTJ, 10
Amplified Bible
THE LETTER OF PAUL TO THE
COLOSSIANS
1
PAUL, AN apostle (special messenger) of Christ Jesus (the
Messiah), by the will of God, and Timothy [our] brother,
2 To the saints (the consecrated people of God) and abelieving
and faithful brethren in Christ who are at Colossae: Grace (spiri-
tual favor and blessing) to you and [heart] peace from God our
Father.
3 We bcontinually give thanks to God the Father of our Lord
jesus Christ (the Messiah), as we are praying for you,
4 For we have heard of your faith in Christ Jesus [ct:he leaning of
your entire human personality on Him in absolute trust and confi-
dence in His power, wisdom, and goodness] and of the love which
you [have and show] for all the saints (God's consecrated ones),
5 Because of the hope [of experiencing what is] laid up
(dreserved and waiting) for you in heaven. Of this [hope] you
heard in the past in the message of the truth of the Gospel,
6 Which has come to you. Indeed, in the whole world [that
Gospel] is bearing fruit and still is growing
8
[by its own inherent
power], even as it has done among yourselves ever since the day
you first heard and carne to know and understand the grace of
God in truth. [You came to know the grace or undeserved favor of
God in reality, deeply and clearly and thoroughly, becoming accu-
rately and intimately acquainted with it.]
7 You so learned it from Epaphras, our beloved fellow servant.
He is a faithful minister of Christ in our stead and as our repre-
sentative and !Yours.
8 Also he has informed us of your love in the [Holy] Spirit.
9 For this reason we also, from the day we heard of it, have
not ceased to pray and make (Yspecial] request for you, [asking]
that you may be filled with the hfull (deep and clear) knowledge
of His will in all spiritual wisdom [iin comprehensive insight into
the ways and purposes of God] and in understanding and dis-
cernment of spiritual things-
1088
King James Version
THE EPISTLE OF ST. PAUL TO THE
COLOSSIANS
1
Paul, an apostle of jesus Christ by the will of God, and
Tirnotheus our brother,
2 To the saints and faithful brethren in Christ which are at
Colosse: Grace be unto you, and peace, from God our Father and
the Lord jesus Christ.
3 We give thanks to God and the Father of our Lord Jesus
Christ, praying always for you,
4 Since we heard of your faith in Christ jesus, and of the love
whichye have to all the saints,
5 For the hope which is laid up for you in heaven, whereof ye
heard before in the word of the truth of the gospel;
6 Which is come unto you, as it is in all the world; and
bringeth forth fruit, as it doth also in you, since the day ye heard
Q/it, and knew the grace of God in truth:
7 As ye also learned of Epaphras our dear fellowservant, who
is for you a faithful minister of Christ;
8 Who also declared unto us your love in the Spirit.
9 For this cause we also, since the day we heard it, do not
cease to pray for you , and to desire that ye might be filled with
the knowledge of his will in all wisdom and spiritual understand-
ing;
Rheims New Testament
THE EPISTLE OF ST. PAUL TO THE
COLOSSIANS
1
Paul, an apostle of jesus Christ, by the will of God, and
Timothy, a brother,
2 To the saints and faithful brethren in Christ jesus, who are
at Colossa.
3 Grace be to you and peace from God our Father, and from
the Lord Jesus Christ. We give thanks to God, and the Father of
our Lord Jesus Christ, praying always for you.
4 Hearing your faith in Christ jesus, and the love which you
have towards all the saints.
5 For the hope that is laid up for you in heaven, which you
have heard in the word of the truth of the gospel,
6 Which is come unto you, as also it is in the whole world,
and bringeth forth fruit and groweth, even as it doth in you,
since the day you heard and knew the grace of God in truth.
7 As you learned of Epaphras, our most beloved fellow ser-
vant, who is for you a faithful minister of Christ jesus;
8 Who also hath manifested to us your love in the spirit.
9 Therefore we also, from the day that we heard it, cease not
to pray for you, and to beg that you may be filled with the knowl-
edge of his will, in all wisdom, and spiritual understanding:
AB: a Marvin Vincent, Word Studies in the New Testament. b Marvin
Vincent, Word Studies in the New Testament: "Continually belongs with
"give thanks,'" not elsewhere. c Alexander Souter, Pocket Lexicon qfthe
Greek New Testament. d Marvin Vincent, Word Studies in the New
Testament. e Alexander Souter, Pocket Lexicon. J Many ancient manu-
scripts read ""yours."" g Marvin Vincent, Word Studies in the New
Testament. h Marvin Vincent, Word Studies in the New Testament.
i Alexander Souter, Pocket Lexicon.
48
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
1089
New American Standard Bible
THE EPISTLE OF PAUL TO THE
COLOSSIANS
1
Paul, an apostle of jesus Christ by the will of God. and
Timothy our brother,
2 to the saints and faithful brethren in Christ who are at
Colossae: Grace to you and peace from God our Father.
3 We give thanks to God, the Father of our Lord jesus Christ,
praying always for you,
4 since we heard of your faith in Christ jesus and the love
which you have for all the saints;
5 because of the hope laid up for you in heaven, of which you
previously heard in the word of truth, the gospel,
6 which has come to you, just as in all the world also it is con-
stantly bearing fruit and increasing, even as it has been doing in
you also since the day you heard Q/ it and understood the grace
of God in truth;
7 just as you learned it from Epaphras, our beloved fellow
bond-servant, who is a faithful servant of Christ on tour behalf,
8 and he also informed us of your love in the Spirit.
9 For this reason also, since the day we heard Q/ it, we have
not ceased to pray for you and to ask that you may be filled with
the knowledge of His will in all spiritual wisdom and under-
standing,
I Some later mss. readyour
New American Bible
THE LETTER TO THE
COLOSSIANS
1
Paul, an apostle of Christ jesus by the will of God, and
Timothy our brother, 2to the holy ones and faithful brothers
in Christ in Colossae: grace to you and peace from God our
Father.
3We always give thanks to God, the Father of our Lord jesus
Christ, when we pray for you, 4for we have heard of your faith in
Christ jesus and the love that you have for all the holy ones
Sbecause of the hope reserved for you in heaven. Of this you have
already heard through the word of truth, the gospel, 6that has
come to you. just as in the whole world it is bearing fruit and
growing, so also among you, from the day you heard it and came
to kr-ww the grace of God in truth, 7as you learned it from
Epaphras our beloved fellow slave, who is a trustworthy minister
of Christ on your behalf Band who also told us of your love in the
Spirit. .
9Therefore, from the day we heard this, we do not cease pray-
ing for you and asking that you may be filled with the knowledge
of his will through all spiritual wisdom and understanding toto
COLOSSIANS 1
New International Version
COLOSSIANS
1
Paul, an apostle of Christ jesus by the will of God, and
Timothy our brother,
2To the holy and faithfuJa brothers in Christ at Colosse:
Grace and peace to you from God our Father.b
3We always thank God, the Father of our Lord jesus Christ,
when we pray for you, 4because we have heard of your faith in
Christ jesus and of the love you have for all the saints- Sthe
faith and love that spring from the hope that is stored up for you
in heaven and that you have already heard about in the word of
truth, the gospel 6that has come to you. All over the world this
gospel is bearing fruit and growing, just as it has been doing
among you since the day you heard it and understood God's
grace in all its truth. ?You learned it from Epaphras, our dear fel-
low servant, who is a faithful minister of Christ on ourc behalf,
Band who also told us of your love in the Spirit.
9For this reason, since the day we heard about you, we have
not stopped praying for you and asking God to fill you with the
knowledge of his will through all spiritual wisdom and under-
a 2 Or believing b 2 Some manuscripts Father and the Lord jesus Chn'st
c 7 Some manuscriptsyour
New Revised Standard Version
THE LETTER OF PAUL TO THE
COLOSSIANS
1
Paul, an apostle of Christ jesus by the will of God, and
Timothy our brother,
2 To the saints and faithful brothers and sistersa in Christ in
Colossae:
Grace to you and peace from God our Father.
3 In our prayers for you we always thank God, the Father of
our Lord jesus Christ, 4for we have heard of your faith in Christ
jesus and of the love that you have for all the saints, sbecause of
the hope laid up for you in heaven. You have heard of this hope
before in the word of the truth, the gospel 6that has come to you.
just as it is bearing fruit and growing in the whole world, so it
has been bearing fruit among yourselves from the day you heard
it and truly comprehended the grace of God. 7This you learned
from Epaphras, our beloved fellow servant.b He is a faithful min-
ister of Christ on yourc behalf, Band he has made known to us
your love in the Spirit.
9 For this reason, since the day we heard it, we have not
ceased praying for you and asking that you may be filled with the
knowledge of God'sd will in all spiritual wisdom and understand-
a Gk brothers b Gk slave c Other ancient authorities read our
d Gkh1's
49
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
2 THESSALONIANS 1
Greek New Testament
TIP02: 8E2:2:AAONIKEI2: B
1
TiaDA.os Kal. LLA.ouavos Kal. Tq.t68Eos Tfj EKKATJOLCf
ewaaAOVLKEWV E:v 8E<{i naTpl KQL KUPL4J 'IT]OOU
X pLaT[[>, 2 xapLS' UiJ.LV Kal cino 8EOD naTpos
Kat Kvplou 'IT]aou XpwTov.
3 EuxapLaTELV odA.OiJ.EV T<{j 8E0 TIGVTOTE T!Epl UiJ.WV,
cioEA.cpo(, Ka8ws E:anv, on n(ans
ViJ.wv Kal nA.Eova(EL ciycinTJ Evos EKaaTou ncivTwv u11wv
Ets 4 waTE a1nous E:v ViJ.LV E:yKauxaa8m
E:v Tats EKKAT]aLaLS' TOU 8Eou vnEp ViJ.WV Kal
TILOTEWS' E:v naaw TCfLS' OLWYiJ.OLS' UiJ.WV Kat TaLs 8A.LtjJEaLV
ats civExw8E, 5 EVoEL Ylla EiLKalas KplaEWS' Tou 8Eou
Ets To UiJ.US' Tou 8EOu, vnEp
Kal nciaXETE, 6 ELnEp 8[Kawv napa 8E0 civTano8ouvm
TolS' UiJ.US' 8A.ltj.JLV 7 Kat ujl'iv TolS'
avww iJ.E8' E:v TD cmoKaA.utjJEL Tou Kvplou 'IT]aou cin'
ovpavov jlET' ciyyEAWV bUVQjlEWS' auTOU 8 EV nupL cpA.oyos,
OLOOVTOS' EKbLKT]OLV TOLS' ElbOOLV 8EOV KGL TOLS'
unaKououaLv T0 EuayyEAL4J Tou Kvp[ou 'IT]aou,
Amplified Bible
THE SECOND LETTER OF PAUL TO THE
THESSALONIANS
1
PAUL, SILVANUS (Silas), and Timothy, to the church (assem-
bly) of the Thessalonians in God our Father and the Lord
jesus Christ (the Messiah, the Anointed One):
2 Grace (unmerited favor) be to you and [heart] peace from
God the Father and the Lord jesus Christ (the Messiah, the
Anointed One).
3 We ought and indeed are obligated [as those in debt] to give
thanks always to God for you, brethren, as is fitting, because
your faith is growing exceedingly and the love of every one of
you each toward the others is increasing and abounds.
4 And this is a cause of our mentioning you with pride among
the churches (assemblies) of God for your steadfastness (your
unflinching endurance and patience) and your firm faith in the
midst of all the persecutions and crushing distresses and afflic-
tions under which you are holding up.
5 This is positive proof of the just and right judgment of God
to the end that you may be deemed deserving of His kingdom [a
plain token of His fair verdict which designs that you should be
made and counted worthy of the kingdom of God], for the sake of
which you are also suffering.
6 [It is a fair decision] since it is a righteous thing with God to
repay with distress and affliction those who distress and afflict
you,
7 And to [arecompense] you who are so distressed and afflict-
ed [by granting you] relief and rest along with us [your fellow
sufferers] when the Lord jesus is revealed from heaven with His
mighty angels in a flame of fire,
8 To deal out retribution (chastisement and vengeance) upon
those who do not know or perceive or become acquainted with
God, and [upon those] who ignore and refuse to obey the Gospel
of our Lord jesus Chn"st.
1124
King James Version
THE SECOND EPISTLE OF ST. PAUL TO THE
THESSALONIANS
1
Paul. and Silvanus, and Timotheus, unto the church of the
Thessalonians in God our Father and the Lord jesus Christ:
2 Grace unto you, and peace, from God our Father and the
Lord jesus Christ.
3 We are bound to thank God always for you, brethren, as it is
meet, because that your faith groweth exceedingly, and the chari-
ty of every one of you all toward each other aboundeth;
4 So that we ourselves glory in you in the churches of God for
your patience and faith in all your persecutions and tribulations
that ye endure:
5 Which is a manifest token of the righteous judgment of
God, that ye may be counted worthy of the kingdom of God, for
which ye also suffer:
6 Seeing it is a righteous thing with God to recompense tribu-
lation to them that trouble you;
7 And to you who are troubled rest with us, when the Lord
jesus shall be revealed from heaven with his mighty angels,
8 In flaming fire taking vengeance on them that know not
God, and that obey not the gospel of our Lord jesus Christ:
Rheims New Testament
THE SECOND EPISTLE OF ST. PAUL TO THE
THESSALONIANS
1
Paul, and Sylvanus, and Timothy, to the church of the
Thessalonians in God our Father, and the Lord jesus Christ.
2 Grace unto you, and peace from God our Father, and from
the Lord jesus Christ.
3 We are bound to give thanks always to God for you ,
brethren, as it is fitting, because your faith groweth exceedingly,
and the charity of every one of you towards each other, abound-
eth:
4 So that we ourselves also glory in you in the churches of
God, for your patience and faith, and in all your persecutions and
tribulations, which you endure,
5 For an example of the just judgment of God, that you may
be counted worthy of the kingdom of God, for which also you
suffer.
6 Seeing it is a just thing with God to repay tribulation to
them that trouble you:
7 And to you who are troubled, rest with us when the Lord
jesus shall be revealed from heaven, with the angels of his
power:
8 In a flame of fire, giving vengeance to them who know not
God, and who obey not the gospel of our Lord jesus Christ.
AB: a Raben jamieson, A.R. Fausser and David Brown. A Commentary on
the Old and New rescaments.
50
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
1125
New American Standard Bible
THE SECOND EPISTLE OF ST. PAUL TO THE
THESSALONIANS
1
Paul and Silvanus and Timothy to the church of the
Thessalonians in God our Father and the Lord jesus Christ:
2 Grace to you and peace from God the Father and the Lord
jesus Christ.
3 We ought always to give thanks to God for you, brethren, as
is on{y fitting, because your faith is greatly enlarged, and the love
of each one of you toward one another grows ever greater;
4 therefore, we ourselves speak proudly of you among the
churches of God for your perseverance and faith in the midst of
all your persecutions and afflictions which you endure.
5 This is a plain indication of God's righteous judgment so
that you may be considered worthy of the kingdom of God, for
which indeed you are suffering.
6 For after all it is on{y just for God to repay with affliction
those who afflict you,
7 and to give relief to you who are afflicted and to us as well
when the Lord jesus shall be revealed from heaven with His
mighty angels in flaming fire,
8 dealing out retribution to those who do not know God and to
those who do not obey the gospel of our Lord jesus.
New American Bible
THE SECOND LEITER TO THE
THESSALONIANS
1
Paul, Silvanus, and Timothy to the church of the
Thessalonians in God our Father and the Lord jesus Christ:
2grace to you and peace from God [our] Father and the Lord jesus
Christ.
3We ought to thank God always for you, brothers, as is fitting,
because your faith flourishes ever more, and the love of every one
of you for one another grows ever greater. 4Accordingly, we our-
selves boast of you in the churches of God regarding your
endurance and faith in all your persecutions and the afflictions
you endure.
SThis is evidence of the just judgment of God, so that you may
be considered worthy of the kingdom of God for which you are
suffering. 6For it is surely just on God's part to repay with afflic-
tions those who are afflicting you, ?and to grant rest along with
us to you who are undergoing afflictions, at the revelation of the
Lord jesus from heaven with his mighty angels, Bin blazing fire,
inflicting punishment on those who do not acknowledge God and
on those who do not obey the gospel of our Lord jesus. 9These
2 THESSALONIANS 1
New International Ve rsion
2 THESSALONIANS
1 Paul, Silasa and Timothy,
To the church of the Thessalonians in God our Father and the
Lord jesus Christ:
2Grace and peace to you from God the Father and the Lord
jesus Christ.
3We ought always to thank God for you, brothers, and rightly
so, because your faith is growing more and more, and the love
every one of you has for each other is increasing. 4Therefore,
among God's churches we boast about your perseverance and
faith in all the persecutions and trials you are enduring.
SAil this is evidence that God's judgment is right, and as a
result you will be counted worthy of the kingdom of God, for
which you are suffering. 6God is just: He will pay back trouble to
those who trouble you ?and give relief to you who are troubled,
and to us as well. This will happen when the Lord jesus is
revealed from heaven in blazing fire with his powerful angels.
BHe will punish those who do not know God and do not obey the
a I Greek Silvanus. a variant of Silas
New Revised Standard Version
THE SECOND LEITER OF PAUL TO THE
THESSALONIANS
1
Paul, Silvanus, and Timothy,
To the church of the Thessalonians in God our Father and the
Lord jesus Christ:
2 Grace to you and peace from God oura Father and the Lord
jesus Christ.
3 We must always give thanks to God for you, brothers and
sisters,b as is right, because your faith is growing abundantly,
and the love of everyone of you for one another is increasing.
4Therefore we ourselves boast of you among the churches of God
for your steadfastness and faith during all your persecutions and
the afflictions that you are enduring.
5 This is evidence of the righteous judgment of God, and is
intended to make you worthy of the kingdom of God, for which
you are also suffering. 6For it is indeed just of God to repay with
affliction those who afflict you, ?and to give relief to the afflicted
as well as to us , when the Lord jesus is revealed from heaven
with his mighty angels Bin flaming fire, inflicting vengeance on
those who do not know God and on those who do not obey the
a Other ancient authorities read the b Gk brothers
51
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
2 THESSALONIANS 2, 3
Greek New Testament
'lrpous XpwTOS' Kat [6] 8EOS' 6 rralijp o
Kat 8ous rrapciKA.llaLv aLwv[av Kat EA1TLOa Ev
xcipL TL' 1 7 rrapaKUAEUQL U[lWV TOS KapOLUS' Kat UTllPLEm
Ev rravTL EPY4l Kat Mytp ci.ya80.
3
To A.oLTiov rrpoaEl1xw8E, ci.8EA.<jlo[, rrEpL 'iva 6 M-
yos Tou KUptou TPEXlJ Kat ooEci(llTaL Ka8ws Kat rrpos
V!l-OS, 2 Kat 'iva puaSw[lEV ci.rro Twv ci.T6rrwv Kat 1TOVllPWV
ci.vSpwrrwv ou yap rrcivTwv rrtans. 3 maTos 8E' E:anv 6
K!lpLOS', as aTllPLEEL U[J.as Kat uA.ciEEL ci.rro -iou rrovfJpoiJ.
4 1TE1TOL8a!1-EV OE EV KUpltp E<jl' VIlaS' ' C>TL a rrapayyEAAO!l-EV
[Kat] rroLELTE Kat 5 '0 8 KupLOS' KaTEu8uvm
u11wv Tas Kapotas ELs ci.ycirrw Tou 8EOu Kat ELs
TOU XpLUTOU.
6 TiapayyE'AA.o[lEV 8 U!l-LV, ci8EA.<jlo[, EV ov61wTL Tou
Kup[ou 'l11aou XpwTou aTE'A.A.wSm VIlaS' ci.rro rravTos
ci.8EA.ou cnciKTws rrEpLrraTouvTos Kat KaTa rrapci-
8oaLv rrap' TWWV. 7 UlJTOt yap OlOUTE
rrws 8E"i fl.LflE"iaSm on ouK Ev v!l-"iv
8 OUOE 8wpEaV apTOV E:ci.yo[J.EV rrapci TLVOS', ci.A.A.' EV K01T4J
Kat 116x84J vuKTos Kat Epya(owvm rrpos To
nva U[lwv 9 oux on ouK EXOflEV EEova[av,
ci.A.A' 'Lva E:auTous Turrov owwv Ufl.LV ds- TO fl.LflEI.aSm
10 Kat yap aTE rrpos u11as, ToiJTo rrapmyE'AA.oflEV
U[J.LV, on El TLS ou 8EAEL Epyci(w8m [1T]8E E'a8LETW.
Amplified Bible
16 Now may our Lord jesus Christ Himself and God our Father,
Who loved us and gave us everlasting consolation and encourage-
ment and well-founded hope through [His] grace (unmerited favor),
1 7 Comfort and encourage your hearts and strengthen them
[make them steadfast and keep them unswerving] in every good
work and word.
3
FURTHERMORE, BRETHREN, do pray for us, that the Word
of the Lord may speed on (spread rapidly and run its course)
and be glorified (extolled) and triumph, even as [it has done]
withyou,
2 And that we may be delivered from perverse (improper,
unrighteous) and wicked (actively malicious) men, for not every-
body has faith and is held by it.
3 Yet the Lord is faithful, and He will strengthen [you] and set
you on a firm foundation and guard you from the evil [one] .
4 And we have confidence in the Lord concerning you, that
you are doing and will continue to do the things which we sug-
gest and with which we charge you.
5 May the Lord direct your hearts into [realizing and showing]
the love of God and into the steadfastness and patience of Christ
and ain waiting for His return.
6 Now we charge you, brethren, in the name and on the
authority of our Lord jesus Christ (the Messiah) that you with-
draw and keep away from every brother (fellow believer) who is
slack in the performance of duty and is disorderly, living as a
shirker and not walking in accord with the traditions and instruc-
tions that you have received from us.
7 For you yourselves know how it is necessary to imitate our
example, for we were not disorderly or shirking of duty when we
were with you [we were not idle].
8 Nor did we eat anyone's bread without paying for it, but
with toil and struggle we worked night and day, that we might
not be a burden or impose on any of you [for our support].
9 [It was] not because we do not have a right [to such support],
but [we wished] to make ourselves an example for you to follow.
10 For while we were yet with you, we gave you this rule and
charge: If anyone will not work, neither let him eat.
1130
King }ames Version
16 11 Now our Lord jesus Christ himself. and God, even our
Father, which hath loved us, and hath given us everlasting con-
solation and good hope through grace,
17 Comfort your hearts, and stablish you in every good word
and work.
3
Finally, brethren, pray for us, that the word of the Lord may
have.free course, and be glorified, even as it is with you:
2 And that we may be delivered from unreasonable and
wicked men: for all men have not faith.
3 But the Lord is faithful, who shall stablish you, and keep
you from evil.
4 And we have confidence in the Lord touching you, that ye
both do and will do the things which we command you.
5 And the Lord direct your hearts into the love of God, and
into the patient waiting for Christ.
6 11 Now we command you, brethren, in the name of our Lord
jesus Christ, that ye withdraw yourselves from every brother that
walketh disorderly, and not after the tradition which he received
of us.
7 For yourselves know how ye ought to follow us: for we
behaved not ourselves disorderly among you;
8 Neither did we eat any man's bread for nought; but wrought
with labour and travail night and day, that we might not be
chargeable to any of you:
9 Not because we have not power, but to make ourselves an
ensample unto you to follow us.
10 For even when we were with you, this we commanded you,
that if any would not work, neither should he eat.
Rheims New Testament
15 Now our Lord jesus Christ himself, and God and our
Father, who hath loved us, and hath given us everlasting conso-
lation, and good hope in grace,
16 Exhort your hearts, and confirm you in every good work
and word.
3
For the rest, brethren, pray for us, that the word of God may
run, and may be glorified, even as among you;
2 And that we may be delivered from importunate and evil
men; for all men have not faith.
3 But God is faithful , who will strengthen and keep you from
evil.
4 And we have confidence concerning you in the Lord, that
the things which vye command, you both do, and will do.
5 And the Lord direct your hearts, in the charity of God, and
the patience of Christ.
6 And we charge you, brethren, in the name of our Lord jesus
Christ, that you withdraw yourselves from every brother walking
disorderly, and not according to the tradition which they have
received of us.
7 For yourselves know how you ought to imitate us : for we
were not disorderly among you;
8 Neither did we eat any man's bread for nothing, but in
labour and in toil we worked night and day, lest we should be
chargeable to any of you.
9 Not as if we had not power: but that we might give our:
selves a pattern unto you, to imitate us.
10 For also when we were with you, this we declared to you:
that, if any man will not work, neither let him eat.
AB: a joseph Thayer, A Greek-English Le;a'con Q/ the New Testament.
52
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
New American Standard Bible
16 Now may our Lord jesus Christ Himself and God our Father,
who has loved us and given us eternal comfort and good hope by
grace,
t7 comfort and strengthen your hearts in every good work and
word.
3
Finally, brethren, pray for us that the word of the Lord may
spread rapidly and be glorified, just as it did also with you;
2 and that we may be delivered from perverse and evil men;
for not all have faith.
3 But the Lord is faithful, and He will strengthen and protect
you from the evil one.
4 And we have confidence in the Lord concerning you, that
you are doing and will continue to do what we command.
5 And may the Lord direct your hearts into the love of God and
into the steadfastness of Christ.
6 Now we command you , brethren, in the name of our Lord
Jesus Christ, that you keep aloof from every brother who leads an
unruly life and not according to the tradition which you received
from us.
7 For you yourselves know how you ought to follow our exam-
ple, because we did not act in an undisciplined manner among
you,
B nor did we eat anyone's bread without paying for it, but with
labor and hardship we kept working night and day so that we
might not be a burden to any of you;
9 not because we do not have the right to this, but in order to
offer ourselves as a model for you, that you might follow our
example.
10 For even when we were with you, we used to give you this
order: if anyone will not work, neither let him eat.
New American Bible
' J6May our Lord jesus Christ himself and God our Father, who
has loved us and given us everlasting encouragement and good
hope through his grace, I?encourage your hearts and strengthen
them in every good deed and word.
-3 Finally, brothers, pray for us, so that the word of the Lord
may speed forward and be glorified, as it did among you,
2and that we may be delivered from perverse and wicked people,
for not all have faith. 3But the Lord is faithful; he will strengthen
you and guard you from the evil one. 4We are confident of you
i_n the Lord that what we instruct you, you [both] are doing and
will continue to do. sMay the Lord direct your hearts to the love
of God and to the endurance of Christ.
6We instruct you, brothers, in the name of [our] Lord jesus
Christ, to shun any brother who conducts himself in a disorderly
way and not according to the tradition they received from us.
?for you know how one must imitate us. For we did not act in a
disorderly way among you, snor did we eat food received free
from anyone. On the contrary, in toil and drudgery, night and
day we worked, so as not to burden any of you. 9Not that we do
not have the right. Rather, we wanted to present ourselves as a
model for you, so that you might imitate us. wrn fact, when we
were with you, we instructed you that if anyone was unwilling
to work, neither should that one eat. 1 JWe hear that some are
2 THESSALONIANS 2, 3
New International Version
16May our Lord jesus Christ himself and God our Father, who
loved us and by his grace gave us eternal encouragement and
good hope, 1 ?encourage your hearts and strengthen you in every
good deed and word.
3
Finally, brothers, pray for us that the message of the Lord
may spread rapidly and be honored, just as it was with you.
2And pray that we may be delivered from wicked and evil men,
for not everyone has faith . 3But the Lord is faithful, and he will
strengthen and protect you from the evil one. 4We have confi -
dence in the Lord that you are doing and will continue to do the
things we command. SMay the Lord direct your hearts into God's
love and Christ's perseverance.
6]n the name of the Lord Jesus Christ, we command you, broth-
ers, to keep away from every brother who is idle and does not
live according to the teachinga you received from us.
7
For you
yourselves know how you ought to follow our example. We were
not idle when we were with you, snor did we eat anyone's food
without paying for it. On the contrary, we worked night and day,
laboring and toiling so that we would not be a burden to any of
you. 9We did this, not because we do not have the right to such
help, but in order to make ourselves a model for you to follow.
IDFor even when we were with you, we gave you this rul e: "If a
man will not work, he shall not eat."
a 6 Or tradition
New Revised Standard Version
16 Now may our Lord Jesus Christ himself and God our
Father, who loved us and through grace gave us eternal comfort
and good hope, 1 ?comfort your hearts and strengthen them in
every good work and word.
3
Finally, brothers and sisters,a pray for us, so that the word of
the Lord may spread rapidly and be glorified everywhere, just
as it is among you, 2and that we may be rescued from wicked
and evil people; for not all have faith. 3But the Lord is faithful;
he will strengthen you and guard you from the evil one.b 4And
we have confidence in the Lord concerning you, that you are
doing and will go on doing the things that we command. SMay
the Lord direct your hearts to the love of God and to the stead-
fastness of Christ.
6 Now we command you, beloved,a in the name of our Lord
Jesus Christ, to keep away from believers who arec living in idle-
ness and not according to the tradition that theyd received from
us. ?for you yourselves know how you ought to imitate us; we
were not idle when we were with you, sand we did not eat any-
one's bread without paying for it; but with toil and labor we
worked night and day, so that we might not burden any of you.
9This was not because we do not have that right, but in order to
give you an example to imitate. IDfor even when we were with
you, we gave you this command: Anyone unwilling to work
a Gk brothers b OrJrom evil c GkJrom every brother who is d Other
anciem authorities readyou
53
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
PHILEMON
Greek New Testament
TIPOL: 8IAHMONA
1 nau>..os 8ECJ[1LOS' XpWTOU 'lT]CJOU Kai TL[108EOS' 6
ci.8EA.os <lhAi)[lOIJL Tc{J ci.yaTTT]Tc{J Kat CJUVEpyc{J TJ[lWIJ 2 Kat
'An[q ci.8EAfj Kal 'ApXLTTTTl[J Tc{J CJUCJTpanWT\] TJ[lWIJ
Kat Tfj KaT' OLKOIJ CJOU EKKAT]CJLc;t, 3 xci.pLS' U[lLIJ Kat Elpi]vT]
ci.no 8EoD naTpos TJflWV Kat Kup(ou 'IT]aou XpwTou.
4 EuxapwTw T0 8E0 f1ou navToTE flvdav aou nmou-
f1Evos ETTL TUJV TTpOCJEUXWIJ [lOU, 5 aKOUWIJ CJOU ci.yci.TTT]IJ
Kat n(anv, EXELS' npos Tov KUpLov 'lT]CJOuv Kat Els
navTaS' TOUS' ay(ous, 6 OTTWS' Tj KOLIJWIJLQ Tf)S' TTLCJTEWS' CJOU
yEvT]TaL Ev EmyvwCJEL navTOS' ci.ya8oD TOU Ev TJ[lLV
ELS' XpLCJTOIJ. 7 xapav yap ECJXOV KQL napaKAT]CJLIJ
ETTL Tfj ci.yci.TT\] CJOU, OTL Tel CJTTAciyxva TCJV ay[wv CJ.VaTTE-
TTaUTaL 8La CJOU, ci.8EAE.
8 LlLo Ev XpwT0 nappT]atav EXWV Em TaaaELV aoL
TO ci.vf}KOv 9 8u1 ci.yci.TTT]V [J.Ci.>..Aov napaKaA.w, TOLOUTOS'
wv ws Dai:>>..os vuv\_ 8 Kat 8Eaf1LOS' XpwTou
'IT]aou 10 napaKa>..w aE TTEpi Tou E[lOU TEKvou, ov Eyt:'v-
VT]Ga EV TOLS' 8Ea[lOLS', 'OvTjaL[lOV, 11 TOV TTOTE aoL
axpTJGTOV vvv\. 8 [Kal.] aol. KQL E[lOL EUXPTJGTOV, 12 OIJ
Amplified Bible
THE LETTER OF PAUL TO
PHILEMON
PAUL, A prisoner [for the sake] of Christ jesus (the Messiah),
and our brother Timothy, to Philemon our dearly beloved sharer
with us in our work,
2 And to Apphia our sister and Archippus our fellow soldier
[in the Christian warfare], and to the church [assembly that
meets] in your house:
3 Grace (spiritual blessing and favor) be to all of you and [heart]
peace from God our Father and the Lord jesus Christ (the Messiah).
4 I give thanks to my God for you always when I mention you
in my prayers,
5 Because I continue to hear of your love and of your loyal
faith which you have toward the Lord jesus and [which you
show] toward all the saints (God's consecrated people).
6 [And I pray] that the participation in and sharing of your faith
may produce and promote full recognition and appreciation and
understanding and precise knowledge of every good [thing] that is
ours in [our identification with] Christ jesus [and unto His glory].
7 For I have derived great joy and comfort and encouragement
from your love, because the hearts of the saints [who are your
fellow Christians] have been cheered and refreshed through you,
[my] brother.
8 Therefore, though I have abundant boldness in Christ to
charge you to do what is fitting and required and your duty
to do,
9 Yet for love's sake I prefer to appeal to you just for what I
am-I, Paul, an ambassador [of Christ jesus] and an old man and
now a prisoner for His sake also-
tO I appeal to you for my [own spiritual] child, Onesimus
[meaning profitable], whom I have begotten [in the faith] while a
captive in these chains.
11 Once he was unprofitable to you. but now he is indeed
profitable to you as well as to me.
1182
King James Version
THE EPISTLE OF ST. PAUL TO
PHILEMON
11 Paul , a prisoner of jesus Christ, and Timothy our brother,
unto Philemon our dearly beloved, and fellowlabourer,
2 And to our beloved Apphia, and Archippus our fellowsoldier,
and to the church in thy house:
3 Grace to you, and peace, from God our Father and the Lord
jesus Christ.
4 111 thank my God, making mention of thee always in my
prayers,
5 Hearing of thy love and faith, which thou hast toward the
Lord jesus, and toward all saints;
6 That the communication of thy faith may become effectual
by the acknowledging of every good thing which is in you in
Christ jesus.
7 For we have great joy and consolation in thy love, because
the bowels of the saints are refreshed by thee, brother.
8 11 Wherefore, though I might be much bold in Christ to
enjoin thee that which is convenient,
9 Yet for love's sake I rather beseech thee, being such an one
as Paul the aged, and now also a prisoner of jesus Christ.
10 1 beseech thee for my son Onesimus, whom I have begotten
in my bonds:
11 Which in time past was to thee unprofitable, but now prof-
itable to thee and to me:
Rheims New Testament
THE EPISTLE OF ST. PAUL TO
PHILEMON
Paul, a prisoner of Christ jesus, and Timothy, a brother: to
Philemon, our beloved and fellow labourer;
2 And to Appia, our dearest sister, and to Archippus, our fel-
low soldier, and to the church which is in thy house:
3 Grace to you and peace from God our Father, and from the
Lord jesus Christ.
4 I give thanks to my God, always making a remembrance of
thee in my prayers.
5 Hearing of thy charity and faith, which thou hast in the
Lord jesus, and towards all the saints:
6 That the communication of thy faith may be made evident in
the acknowledgment of every good work, that is in you in Christ
jesus.
7 For I have had great joy and consolation in thy charity,
because the bowels of the saints have been refreshed by thee,
brother.
8 Wherefore though 1 have much confidence in Christ jesus, to
command thee that which is to the purpose:
9 For charity sake I rather beseech, whereas thou art such a
one, as Paul an old man, and now a prisoner also of jesus Christ.
10 I beseech thee for my son, whom I have begotten in my
bands, Onesimus,
11 Who hath been heretofore unprofitable to thee, but now is
profitable both to me and thee,
54
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
New American Standard Bible
THE EPISTLE OF PAUL TO
PHILEMON
i Paul, a prisoner of Christ jesus, and Timothy our brother, to
philemon our beloved brother and fellow worker,
z and to Apphia our sister, and to Archippus our fellow sol-
Mer, and to the church in your house:
Grace to you and peace from God our Father and the Lord
esus Christ.
I thank my God always, making mention of you in my
,rayers. . .
5 because I hear of your love, and of the fanh whtch you have
0
ward the Lord jesus, and toward all the saints;
6
1
and I pray that the fellowship of your faith may become
effective 1through the knowledge of every good thing which is in
for Christ's sake.
.,- '/t For I have come to have much joy and comfort in your love,
lleeause the hearts of the saints have been refreshed through you,
.
.JS< Therefore, though I have enough confidence in Christ to
e'rder you to do that which is proper,
9 'yet for love's sake I rather appeal to you-since I am such a
p,efson as Paul, the aged, and now also a prisoner of Christ
jesus-
10 .I appeal to you for my child, whom I have begotten in my
imprisonment, JQnesimus,
jJ 1 who formerly was useless to you, but now is useful both to
you and to me.
f, Or, in 2 Some ancient mss. read us 3 I.e .. useful
New American Bible
THE LETTER TO
PHILEMON
1
,)'Paul, a prisoner for Christ jesus, and Timothy our brother, to
Jlhilemon, our beloved and our co-worker, 2to Apphia our sister,
'l\Archippus our fellow soldier, and to the church at your house.
to you and peace from God our Father and the Lord jesus
nrist.
1
give thanks to my God always, remembering you in my
prayers, sas I hear of the love and the faith you have in the Lord
and for all the holy ones, 6so that your partnership in the
may become effective in recognizing every good there is in
leads to Christ.
a 7for I have experienced much joy and encouragement from
love, because the hearts of the holy ones have been
by you, brother. BTherefore, although I have the full
right in Christ to order you to do what is proper, 9J rather urge
you out of love, being as I am, Paul, an old man, and now also a
pr.iponer for Christ jesus. IOJ urge you on behalf of my child
9n"esimus, whose father I have become in my imprisonment ,
11
who was once useless to you but is now useful to [both] you
PHILEMON
New International Version
PHILEMON
1
Paul, a prisoner of Christ jesus. and Timothy our brother,
To Philemon our dear friend and fellow worker, 2to Apphia our
sister, to Archippus our fellow soldier and to the church that
meets in your home:
3Grace to you and peace from God our Father and the Lord
jesus Christ.
4I always thank my God as I remember you in my prayers,
Sbecause I hear about your faith in the Lord jesus and your love
for all the saints. 6J pray that you may be active in sharing your
faith, so that you will have a full understanding of every good
thing we have in Christ. ?Your love has given me great joy and
encouragement, because you, brother, have refreshed the hearts
of the saints.
BTherefore, although in Christ I could be bold and order you to
do what you ought to do, 9yet I appeal to you on the basis of
love. I then, as Paul-an old man and now also a prisoner of
Christ jesus- IOI appeal to you for my son Onesimus,a who
became my son while I was in chains. II Formerly he was useless
to you, but now he has become useful both to you and to me.
a 10 Onesimus means usiful.
New Revised Standard Version
THE LETTER OF PAUL TO
PHILEMON
Paul, a prisoner of Christ jesus, and Timothy our brother,a
To Philemon our dear friend and co-worker, 2to Apphia our
sister,b to Archippus our fellow soldier, and to the church in your
house:
3 Grace to you and peace from God our Father and the Lord
jesus Christ.
4 When I remember youc in my prayers, I always thank my
God sbecause I hear of your love for all the saints and your faith
toward the Lord jesus. 6J pray that the sharing of your faith may
become effective when you perceive all the good that wed may do
for Christ. 7I have indeed received much joy and encouragement
from your love, because the hearts of the saints have been
refreshed through you, my brother.
8 For this reason, though I am bold enough in Christ to com-
mand you to do your duty, 9yet I would rather appeal to you on
the basis of love-and I, Paul, do this as an old man, and now
also as a prisoner of Christ jesus.e IOJ am appealing to you for
my child, Onesimus, whose father I have become during my
imprisonment. Itformerly he was useless to you, but now he is
indeed useful' both to you and to me. I7. J am sending him, that
a Gk the brother b Gk the sisrer c From verse 4 through verse 21 ,you
is singular d Other ancient authorities readyou (plural) e Or as an
ambassador if Chn'st jesus, and now also his pn'soner J The name
Onesimus means us.11 or (compare verse 20) benijicial
55
PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
jAMES 1, 2
Greek New Testament
cmoi:os 25 6 6E: napaKvtjJas Els llO!lOll TEAELOll TOll Tf)S'
EAEu8Ep(as Kal napallELvas, OtJK EmAT")GilOllf)S'
yEvollEvos ci\1--a Epyou, ouTos llaKcipt os e'v Tfj
TIOl Ql!TOU EO"TUL.
26 E'( TlS' bOKEL 8pT]O"KOS' ELllat xaAtvayc.uywv y\waaall
a-lnou ciA'"-a cinaTwv Kap8tall ainou, TOVTou 11ciTmos 8pTJ-
aKda. 27 8pT]OKELa Ka8apa Kat clll laVTOS' ;mpa T0 8E0 Kat
TiaTpl QUTT] EO"Tlll, ETILO"KETITE0"8at 6pallOUS' Kat Ell
Tij 81--LtjJEl alJTWll, aam.AOV E:auTOV TTJPELV cino TOU KOO"!lOU.
2
'A8EA<j>o( !lOU, 11il Ell npoawTIOATJiltjJLatS' EXETE Ti]v n(anv
Tou KVptou

' IYJaou XpwTou Tfis 2 E:a.v yap
El.oE:A81J ELS' avvaywyr]V u11wv civi]p xpuao8aKTDALOS' EV Ea8f)Tt
ElaEA81J 8E: Kal. TITWXOS' Ell E:a8f)n, 3 E:m-
8E: E:nt TOll opoullTa Tijll Ea8f)Ta Tijll AallTIPclll Kat
E'L TIT]TE, L;u Kci8ou w8E KaAWS', Kai. T0 TITWX0 d TIT]TE, "l:u
aTf)8t EKE'i Kci8ou uno To unon68toll !lOU, 4 ou 8tEKpL8TJTE
Ell E:auTo"is Kat E:yE:vw8E Kpt Tat TTOllTJPWll;
5 'AKouoaTE , ci8EA<j>o( 110u ciyaTTTJTOL" oux 6 8EOS'
TOUS' TITwxous T0 KOO" Il4l nAoua(ous EV TILO"TEt Kat
KATJpOVO!lOUS' Tf)S' ETITJYYELAaTo TOtS' ciyanwmv
QUTOll; 6 UllELS' OE TOll TITWXOV. oux oL TIAOU-
O"LOL KaTa8vvaaTEvouatv UllWV Kai. auTot EAKOUOLV UJlO.S' ELS'
KpL 7 ouK mhot TO KaMv ovo11a TO
Amplified Bible
25 But he who looks carefully into the faultless law, the [law]
of liberty, and is faithful to it and perseveres in looking into it,
being not a heedless listener who forgets but an active doer [who
obeys], he shall be blessed in his doing (his life of obedience).
26 If anyone thinks himself to be religious (piously observant
of the external duties of his faith) and does nor bridle his tongue
but deludes his own heart, this person' s religious servi ce is
worthless (futile, barren).
27 External ereligious worship ['religion as it is expressed in
ourward acts] that is pure and unblemished in the sight of God
the Father is this: to visit and help and care for the orphans and
widows in their affliction and need, and to keep oneself unspot-
ted and uncontaminated from the world.
2
MY BRETHREN, pay no servile regard to people [show no
prejudice, no partiality]. Do nor [attempt to] hold and practice
the faith of our Lord jesus Christ [the Lord] of glory [together
with snobbery]!
2 For if a person comes into your congregation whose hands
are adorned with gold rings and who is wearing splendid appar-
el, and also a poor [man] in shabby clothes comes in,
3 And you pay special attention to the one who wears the
splendid clothes and say to him, Sit here in this preferable seat!
while you tell the poor [man] , Stand there! or, Sit there on the
floor at my feet!
4 Are you not discriminating among your own and becoming
critics and judges with wrong motives?
5 Listen, my beloved brethren: Has not God chosen those who
are poor in the eyes of the world to be rich in faith and in their
position as believers and to inherit the kingdom which He has
promised to those who love Him?
6 But you [in contrast] have insulted (humiliated, dishonored,
and shown your contempt for) the poor. Is it not the rich who
domineer over you? Is it not they who drag you into the law
courts?
7 Is it not they who slander and blaspheme that precious
name by which you are distinguished and called [the name of
Christ invoked in baptism]?
1252
King James Version
25 But whoso looketh into the perfect law of liberty, and con-
rinuerh therein, he being not a forgetful hearer, but a doer of the
work, this man shall be blessed in hi s deed.
26 If any man among you seem to be religious, and bridleth
not his tongue, but deceiveth his own heart, this man's religion
is vain.
2 7 Pure religion and undefiled before God and the Father is
this , To visit the fatherless and widows in their affliction. and to
keep himself unspotted from the world.
2
My brethren, have not the faith of our Lord jesus Christ , the
Lord of glory, with respect of persons.
2 For if there come unto your assembly a man with a gold
ring, in goodly apparel, and there come in also a poor man in vile
raiment;
3 And ye have respect to him that weareth the gay clothing,
and say unto him, Sit thou here in a good place; and say to the
poor, Stand thou there, or sit here under my footstool:
4 Are ye nor then partial in yourselves. and are become judges
of evil thoughts?
5 Hearken, my beloved brethren, Hath not God chosen the
poor of this world rich in faith, and heirs of the kingdom which
he hath promised to them that love him?
6 But ye have despised the poor. Do not rich men oppress you,
and draw you before the judgment seats?
7 Do not they blaspheme that worthy name by the which ye
are called?
Rheims New Testament
25 Bur he that hath looked into the perfect law of liberty, and
hath continued therein, not becoming a forgetful hearer, but a
doer of the work; this man shall be blessed in his deed.
26 And if any man think himself to be religious. not bridling
his tongue, but deceiving his own heart, this man's religion is
vain.
27 Religion clean and undefiled before God and the Father, is
this: to visit the fatherless and widows in their tribulation: and to
keep one's self unspotted from this world.
2
My brethren, have not the faith of our Lord jesus Christ of
glory with respect of persons.
2 For if there shall come into your assembly a man having a
golden ring, in fine apparel, and there shall come in also a poor
man in mean attire,
3 And you have respect to him that is clothed with the fine
apparel, and shall say to him: Sit thou here well; but say to the
poor man: Stand thou there, or sit under my footstool:
4 Do you not judge within yourselves, and are become judges
of unjust thoughts?
5 Hearken, my dearest brethren: hath not God chosen the poor
in this world, rich in faith, and heirs of the kingdom which God
hath promised to them that love him?
6 But you have dishonoured the poor man. Do not the rich
oppress you by might? and do not they draw you before the judg-
ment seats?
7 Do not they blaspheme the good name that is invoked upon
you?
AB: e Robert jamieson, A.R. Fausset and David Brown, A Com men cary on
che Old and New Testaments: "Religion in its rise interests us about
ourselves; in its progress, about our fellow creatures; in its highest stage,
about the honor of God. " J G. Abbott-Smi th, Manual Greek Lexicon Q/the
New Testament.
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PLAINTIFFS' APPENDIX OF OUT-OF-STATE AND OTHER SOURCES
1253
New American Standard Bible
25 But one who looks intently at the perfect law. the law of lib-
erty, and abides by it, not having become a forgetful hearer but
an effectual doer, this man shall be blessed in what he does.
26 If anyone thinks himself to be religious, and yet does not bri-
dle his tongue but deceives his own heart, this man's religion is
worthless.
27 This is pure and undefiled religion in the sight of our God
and Father, to visit orphans and widows in their distress, and to
keep oneself unstained by the world.
2
My brethren, do not hold your faith in our glorious Lord jesus
Christ with an attitude if personal favoritism.
2 For if a man comes into your assembly with a gold ring and
dressed in fine clothes, and there also comes in a poor man in
dirty clothes,
3 and you pay special attention to the one who is wearing the
fine clothes, and say, "You sit here in a good place," and you say
to the poor man, "You stand over there, or sit down by my foot-
stool,"
4 have you not made distinctions among yourselves , and
become judges with evil motives?
5 Listen, my beloved brethren: did not God choose the poor of
this world to be rich in faith and heirs of the kingdom which He
promised to those who love Him?
6 But you have dishonored the poor man. Is it not the rich
who oppress you and personally drag you into court?
7 Do they not blaspheme the fair name by which you have
been called?
New American Bible
zsBut the one who peers into the perfect law of freedom and per-
severes, and is not a hearer who forgets but a doer who acts,
such a one shall be blessed in what he does.
Z6If anyone thinks he is religious and does not bridle his
tongue but deceives his heart, his religion is vain. 27Religion that
is pure and undefiled before God and the Father is this: to care
for orphans and widows in their affliction and to keep oneself
unstained by the world.
2
My brothers, show no partiality as you adhere to the faith in
our glorious Lord jesus Christ. ZFor if a man with gold rings
on his fingers and in fine clothes comes into your assembly, and
a poor person in shabby clothes also comes in, 3and you pay
attention to the one wearing the fine clothes and say, "Sit here,
please," while you say to the poor one, "Stand there," or "Sit at
my feet," 4have you not made distinctions among yourselves and
become judges with evil designs?
susten, my beloved brothers. Did not God choose those who
are poor in the world to be rich in faith and heirs of the kingdom
that he promised to those who love him? 6But you dishonored
the poor person. Are not the rich oppressing you? And do they
themselves not haul you off to court? ?Is it not they who blas-
pheme the noble name that was invoked over you? BHowever, if
jAMES 1, 2
New International Version
the perfect law that gives freedom, and continues to do this, not
forgetting what he has heard, but doing it-he will be blessed in
what he does.
26If anyone considers himself religious and yet does not keep a
tight rein on his tongue, he deceives himself and his religion is
worthless. 27Religion that God our Father accepts as pure and
faultless is this: to look after orphans and widows in their dis-
tress and to keep oneself from being polluted by the world.
2
My brothers, as believers in our glorious Lord jesus Christ,
don't show favoritism. zsuppose a man comes into your
meeting wearing a gold ring and fine clothes, and a poor man in
shabby clothes also comes in. 3Jf you show special attention to
the man wearing fine clothes and say, "Here's a good seat for
you," but say to the poor man , "You stand there" or "Sit on the
floor by my feet," 4have you not discriminated among yourselves
and become judges with evil thoughts?
susten, my dear brothers: Has not God chosen those who are
poor in the eyes of the world to be rich in faith and to inherit the
kingdom he promised those who love him? oBut you have insult-
ed the poor. Is it not the rich who are exploiting you? Are they
not the ones who are dragging you into court? ?Are they not the
ones who are slandering the noble name of him to whom you
belong?
New Revised Standard Version
law, the law of liberty, and persevere, being not hearers who for-
get but doers who act-they will be blessed in their doing.
26 If any think they are religious , and do not bridle their
tongues but deceive their hearts, their religion is worthless.
27Religion that is pure and undefiled before God, the Father, is
this: to care for orphans and widows in their distress, and to
keep oneself unstained by the world.
2
My brothers and sisters,a do you with your acts of favoritism
really believe in our glorious Lord jesus Christ?b ZFor if a per-
son with gold rings and in fine clothes comes into your assembly,
and if a poor person in dirty clothes also comes in, 3and if you
take notice of the one wearing the fine clothes and say, "Have a
seat here, please," while to the one who is poor you say, "Stand
there," or, "Sit at my feet, "c 4have you not made distinctions
among yourselves, and become judges with evil thoughts?
susten, my beloved brothers and sisters.d Has not God chosen the
poor in the world to be rich in faith and to be heirs of the king-
dom that he has promised to those who love him? 6But you have
dishonored the poor. Is it not the rich who oppress you? Is it not
they who drag you into court? ?Is it not they who blaspheme the
excellent name that was invoked over you?
a Gk A'[Y brothers b Or hold cheJaich Q/ our glondus Lord jesus Chn'sc
wichout acts Q/Javon'cism c Gk Sit under myJootscool d Gk brothers
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