Brittany and Michael Koper Lawsuit Against TBN

Case 8:15-cv-00139-CJC-JCG Document 1 Filed 01/29/15 Page 1 of 11 Page ID #:1
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Michael W. Koper (CA Bar No. 281422)

mwkoper@icloud.com
100B Haven Ave, #2
Port Washington, NY 11050
Telephone: (949) 500-3316
Attorney for Plaintiffs Michael Koper and Brittany Koper
UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION

MICHAEL KOPER, an individual and
BRITTANY KOPER, an individual,
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Plaintiffs,
vs.
Defendants.
Plaintiff Michael Koper and Plaintiff Brittany Koper allege:
VENUE AND JURISDICTION
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COMPLAINT FOR DAMAGES:

1. UNDER USCA 2520
2. UNDER CAL. PENAL CODE 637.2
3. UNDER CAL. CIV. COE 11708.8
AND DEMAND FOR JURY TRIAL
4. CIVIL CONSPIRACY
TRINITY CHRISTIAN CENTER OF

SANTA ANTA, INC., a corporation,
INTERNATIONAL CHRISTIAN
BROADCASTING, INC., a corporation,
MATTHEW CROUCH, an individual,
JANICE CROUCH, and individual, and
JOHN CASORIA, and individual,
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8:15-cv-00139
Case No: ___________________
1.
This Courts jurisdiction over the subject matter is predicated on 28 U.S.C.
1332. The amount in controversy exceeds $75,000 exclusive of interest and costs.
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2.
This Courts jurisdiction over the subject matter is also predicated on 28
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U.S.C. 1331.
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3.
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U.S.C. 1367.
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4.
This Courts jurisdiction over the subject matter is also predicated on 28

Venue is proper in the Southern Division of the United States District Court
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for the Central District of California. All defendants reside in California, and at least one
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of the defendants resides in this judicial district and division. 28 U.S.C. 1391(a)(1).
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COMPLAINT FOR DAMAGES
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Moreover, a substantial part of the events or omissions giving rise to the claim occurred
in this judicial district and division. 28 U.S.C. 1391(a)(2). Moreover, there is no
district in which the action may otherwise be brought, and at least one of the defendants
is subject to personal jurisdiction in this particular judicial district and division at the time
this action is commenced. 28 U.S.C. 1391(a)(3).
PARTIES
5.
Plaintiff Brittany Koper is and has been a citizen of the State of New York.
Prior thereto, Ms. Koper was a citizen of the State of California at all times mentioned
herein.
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6.
Plaintiff Michael Koper is and has been a citizen of the State of New York.
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Prior thereto, Mr. Koper was a citizen of the State of California at all times mentioned
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herein.
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7.
Defendant Trinity Christian Center of Santa Ana, Inc., which also does
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business as Trinity Broadcasting Network (Defendant Trinity Broadcasting), is and was
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at all times mentioned herein a citizen of the State of California, and no other. Defendant
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Trinity Broadcasting is a corporation formed under the laws of the State of California and
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has its principal place of business in the State of California within the County of Orange.
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8.
Defendant International Christian Broadcasting, Inc., which also does
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business as Heroes Under God (Christian Broadcasting), is and was at all times
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mentioned herein a citizen of the State of California, and no other. Defendant Christian
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Broadcasting is a corporation formed under the laws of the State of Georgia and has it
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principal place of business in the State of California within the County of Orange.
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9.
Defendant Matthew W. Crouch is and was at all times mentioned herein a
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citizen of the State of California, and no other. Defendant Matthew Crouch is a resident
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of Orange County, California.
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10.
Defendant Janice W. Crouch is and was at all times mentioned herein a
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citizen of the State of California, and no other. Defendant Janice Crouch is a resident of
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Orange County, California.
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11.
Defendant John B. Casoria is and was at all times mentioned herein a citizen
of the State of California, and no other. Defendant John Casoria is a resident of Orange
County, California.
12.
Unless otherwise alleged in this complaint, Plaintiffs are informed and
believe, and on the basis of that information and belief allege, that at all times mentioned
in this complaint, Defendants were the agents and employees of their codefendants, and
in doing the things alleged in this complaint, were acting within the course and scope of
that agency and employment.

RELATIONSHIP AMONG THE PARTIES
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Defendant Trinity Broadcasting purports to be the worlds largest Christian
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broadcasting network. Defendant Christian Broadcasting is a nonprofit corporation that
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was formed by Defendant John Casoria and Paul F. Crouch, Sr. as a tax shelter for Paul
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F. Crouch, Sr.s personal money.
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14.
Before she was terminated on or about September 30, 2011, Plaintiff
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Brittany Koper was Defendant Trinity Broadcastings chief financial officer (CFO),
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director of finance, corporate treasurer, and director of human resources. Plaintiff
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Brittany Koper was an officer and director of Christian Broadcasting, as well as the chief
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financial officer, director of finance, corporate treasurer, and director of human resources
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for numerous corporate entities affiliated with Defendant Trinity Broadcasting and
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controlled by the same board of directors.
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15.
Before he was terminated on or about September 30, 2011, Plaintiff Michael
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Koper was Defendant Trinity Broadcastings corporate secretary and vice president of
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media services. Plaintiff Michael Koper was also the corporate secretary for companies
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affiliated with Defendant Trinity Broadcasting and controlled by the same board of
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directors. Plaintiff Michael Koper was a director of Christian Broadcasting.
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16.
Plaintiff Michael Koper and Plaintiff Brittany Koper were husband and wife
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at all times mentioned in this Complaint. Plaintiff Brittany Kopers maiden name is
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Brittany Crouch. She is the granddaughter of Paul Crouch Sr. and Defendant Janice
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Crouch, who were also husband and wife. Defendant Matthew Crouch is the son of
Defendant Janice Crouch.
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Paul Crouch Sr. is and was, at all time mentioned herein, Defendant Trinity
Broadcastings founder, board member, president, and chief executive officer (CEO).
Defendant Janice Crouch is and was, at all times mentioned herein, Defendant Trinity
Broadcastings senior vice president and a board member. Defendant Matthew Crouch is
Defendant Trinity Broadcastings vice president of programming and a board member.
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Paul Crouch Sr., Defendant Janice Crouch, and Defendant Matthew Crouch
maintained control over Defendant Trinity Broadcasting through exclusive and perpetual
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control of Defendant Trinity Broadcastings board of directors. Pursuant to Defendant
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Trinity Broadcastings articles and bylaws, Defendant Trinity Broadcastings board of
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directors is chosen solely by Defendant Trinity Broadcastings members. Circularly,
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though, Defendant Trinity Broadcastings members are defined as and limited to
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Defendant Trinity Broadcastings board of directors. The Crouches thereby elect
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themselves directors and maintain exclusive, perpetual control over Defendant Trinity
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Broadcastings affairs as the companys only members/directors.
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19.
Defendant John Casoria is Defendant Trinity Broadcastings Assistant
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Secretary and General Counsel. He is also Defendant Janice Crouchs nephew and is
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thereby Plaintiff Brittany Kopers first cousin once removed. Plaintiffs are informed,
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believe, and based thereon allege that Defendant John Casoria is the director and senior
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manager of Redemption Strategies, and that this company was formed for the sole
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purpose of maliciously prosecuting, harassing, and intimidating Plaintiff Michael Koper
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and Plaintiff Brittany Koper (as well as members of Plaintiff Michael Kopers family) in
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retaliation after the Kopers reported illegal conduct within Defendant Trinity
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Broadcasting, including unlawful distributions to Defendant Trinity Broadcastings
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members and directors on the order of $100 million.

GENERAL ALLEGATIONS
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20.
At the time she was terminated by Defendants on or about September 30,

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2011, Plaintiff Brittany Koper had served as TBNs Chief Financial Officer (CFO),
Director of Finance, Corporate Treasurer, and Director of Human Resources.
21.
At the time he was terminated by Defendants on or about September 30,
2011, Plaintiff Michael Koper was TBNs Corporate Secretary and Vice President of
Media Services.
22.
Plaintiffs Michael Koper and Plaintiff Brittany Koper allege that Defendants
wrongfully terminated Plaintiffs employment in violation of the public policies of the
State of California and of the United States of America. Plaintiffs allege that such
terminations were in retaliation for (a) Plaintiffs refusal to participate in conduct within
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Defendant Trinity Broadcasting made unlawful by the laws of California and the United
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States and (b) reporting such unlawful conduct to Defendant Trinity Broadcastings
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President, board of directors, to senior executive Defendant John Casoria, and to
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Defendant Trinity Broadcastings IRS auditor.
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23.
Plaintiff Brittany Koper was promoted by Defendant Trinity Broadcastings
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board of directors as the companys Chief Financial Officer (CFO) and Director of
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Finance on or about July 5, 2011, and she was appointed as Defendant Trinity
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Broadcastings Corporate Treasurer on or about August 29, 2011.
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promotion, Plaintiff Brittany Koper also continued to serve in her prior job function as
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Defendant Trinity Broadcastings Director of Human Resources.
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Following her
In the weeks following Plaintiff Brittany Kopers promotion, Defendant
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Trinity Broadcastings board of directors and senior executive Defendant John Casoria
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disclosed specific details concerning Defendant Trinity Broadcastings financial affairs to
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Plaintiff Brittany Koper. Plaintiff Brittany Koper was also given full access to company
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records.
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During these weeks, Plaintiff Brittany Koper learned from Defendant Trinity
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Broadcastings board of directors and Defendant John Casoria that Plaintiff Brittany
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Koper had been chosen for the promotion to Defendant Trinity Broadcastings head of
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finance because the directors needed somebody within the family that they could trust
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to keep Defendant Trinity Broadcastings financial skeletons safely in the closet.

26.
Plaintiff Brittany Koper learned through specific instructions from
Defendant Trinity Broadcasting, Defendant Jan Crouch, Defendant Matthew Crouch, and
Defendant John Casoria that the requirements of Plaintiff Brittany Kopers new job
included active participation in numerous illegal schemes that were disclosed to Plaintiff
Brittany Koper following her promotion.
27.
The nature of these illegal activities involved the systematic diversion of
Defendant Trinity Broadcastings charitable assets through unlawful distributions to
Defendant Trinity Broadcastings directors through numerous channels. The magnitude
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of these unlawful and related financial schemes uncovered by or disclosed to Plaintiff
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Brittany Koper is on the order of $100 million.
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28.
Plaintiff Brittany Koper and Plaintiff Michael Koper were terminated by
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Defendant Trinity Broadcasting because they refused to participate in the unlawful
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activities demanded by Defendant Trinity Broadcastings directors and senior executive
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Defendant John Casoria, and for making reports of those unlawful activities.
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29.
Plaintiff Michael Koper and Plaintiff Brittany Koper were specifically
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threatened and intimidated by Defendant Trinity Broadcastings directors and senior
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executive Defendant John Casoria when Plaintiff Michael Koper and Plaintiff Brittany
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Koper stated that these issues needed to be resolved and properly reported to state and
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federal officials. Plaintiff Michael Koper and Plaintiff Brittany Koper were told by
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Defendant Janice Crouch, Defendant Matthew Crouch, and Defendant John Casoria that
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they would have Plaintiff Michael Koper and Plaintiff Brittany Koper arrested and
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prosecuted if they tried to report Defendant Trinity Broadcasting or its directors for
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financial improprieties. Plaintiff Michael Koper and Plaintiff Brittany Koper were
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advised by Defendant John Casoria that they, too, had broken the same laws and that they
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were prohibited as accomplices from reporting alleged crimes outside the company.
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Plaintiff Michael Koper and Plaintiff Brittany Koper were told that they were required to
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go through Defendant Trinity Broadcastings attorneys, only, if they had concerns. And,
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Plaintiff Michael Koper and Plaintiff Brittany Koper were told that Defendant Trinity
Broadcasting would have them arrested for theft if they took any documents to
prosecutors. Defendant John Casoria also told the Plaintiff Michael Koper and Plaintiff
Brittany Koper that they were bound by confidentiality agreements that prohibited them
from reporting any illegal activities, and they were threatened with civil lawsuits.
30.
On or about September 1, 2011, Paul Crouch, Sr. suffered congestive heart
failure and was hospitalized. Defendant Janice Crouch and Defendant Matthew Crouch
kept Paul Crouch, Sr. isolated from the rest of his family during this time and, in
particular, Paul Crouch, Jr., Plaintiff Brittany Koper, and Plaintiff Michael Koper. It was
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during this isolation that Defendant Trinity Broadcastings board of directors announced
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that Plaintiff Michael Koper, Plaintiff Brittany Koper, and her father Paul Crouch, Jr.
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were all fired. When questioned about the termination, Defendant Matthew Crouch began
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tapping the firearm he had brought to the meeting and asked Plaintiff Brittany Koper
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what she thought would happen when she wrote a memo to the board critical of
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Defendant Matthew Crouchs financial improprieties. Defendant Matthew Crouch
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continued tapping the gun he was holding to ensure that Plaintiff Brittany Koper
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recognized the lethal threat being made.
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31.
On January 29, 2014 Plaintiff Michael Koper and Plaintiff Brittany Koper
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discovered, for the first time, that multiple confidential communications they had with
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Paul Crouch, Sr., Defendant Matthew Crouch, and/or Defendant John Casoria were
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recorded by Defendants using an electronic recording device, and that these recordings
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had subsequently been edited and manipulated by Defendants. Defendants then disclosed
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and intentionally used these intercepted communications on multiple occasions.

FIRST CAUSE OF ACTION UNDER USCA 2520
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32.
Paragraphs 1-31 of this complaint are incorporated by reference as though
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fully set forth herein, and this claim under U.S.C.A. 2520 for violation of U.S.C.A.
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2511 is asserted by Plaintiff Michael Koper and Plaintiff Brittany Koper against each of
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the Defendants.
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33.
Based on information and belief all the Defendants either intentionally
intercepted, or procured each other to intercept, the oral communications of Plaintiff
Michael Koper and Plaintiff Brittany Koper as described above.
34.
Based on information and belief, the Defendants intercepted the
communications of Plaintiff Michael Koper and Plaintiff Brittany Koper for the purpose
of violating Cal. Penal Codes 518, 519 and 523.
35.
Based on information and belief, immediately following the interception of
the communications of Plaintiff Michael Koper and Plaintiff Brittany Koper, Defendants
sent, or caused to be sent, letters to Plaintiff Michael Koper, Plaintiff Brittany Koper,
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their family members, and other third-parties or organizations with whom Plaintiff
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Michael Koper and Plaintiff Brittany Koper had dealings. These letters threatened
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Plaintiff Michael Koper, Plaintiff Brittany Koper and their family members with arrest,
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accused them of committing crimes, and imputed crimes to them.
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36.
Based on information and belief, the Defendants sent these letters for the
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purpose of extorting and obtaining money and property from Plaintiff Michael Koper and
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Plaintiff Brittany Koper.
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37.
Based on information and belief, in addition to these letters, Defendants
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made, or caused to be made, multiple e-mail writings that threatened Plaintiff Michael
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Koper, Plaintiff Brittany Koper and their family members with arrest, accused them of
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committing crimes, and imputed crimes to them.
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Based on information and belief, the Defendants sent these e-mail writings
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for the purpose of extorting and obtaining money and property from Plaintiff Michael
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Koper and Plaintiff Brittany Koper.
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39.
Based on information and belief, Defendants intercepted, disclosed and
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intentionally used the oral communications of Plaintiff Michael Koper and Plaintiff
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Brittany Koper on numerous occasions in violation U.S.C.A. 2511 and are entitled to
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bring a civil action under U.S.C.A. 2520.
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SECOND CAUSE OF ACTION UNDER CAL. PENAL CODE 637.2
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fully set forth herein, and this claim under Cal. Penal Code 637.2 for violation of Cal.
Penal Code 632 is asserted by Plaintiff Michael Koper and Plaintiff Brittany Koper
against each of the Defendants.
41.
As set forth above, Plaintiff Michael Koper, Plaintiff Brittany Koper, Paul
Crouch, Sr., Defendant Matthew Crouch, and/or Defendant John Casoria had several
meetings and communications related to Defendant Trinity Broadcastings financial
improprieties, which led to meetings related to Plaintiff Michael Kopers and Plaintiff
Brittany Kopers terminations.
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42.
These meetings all took place only among these five corporate officers, one
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of whom is TBNs general counsel, in the secure and locked Presidents Conference
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Room of TBN located in Tustin, CA.
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43.
Based on information and belief, Defendants intentionally recorded these
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confidential communications using an electronic recording device without the consent of
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Plaintiff Michael Koper and Plaintiff Brittany Koper in violation of Cal. Penal Code 632
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and are entitled to bring a civil action under Cal. Penal Code 637.2.
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THIRD CAUSE OF ACTION UNDER CAL. CIV. CODE 11708.8

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fully set forth herein, and this claim under Cal. Civ. Code 11708.8 is asserted by
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Plaintiff Michael Koper and Plaintiff Brittany Koper against each of the Defendants.
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45.
As detailed above, Plaintiff Michael Koper and Plaintiff Brittany Koper
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participated in meetings in the locked and secure Presidents Conference Room regarding
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Defendant Trinity Broadcastings, Defendant Matthew Crouchs, and Defendant Janice
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Crouchs financial improprieties.
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46.
During these meetings Plaintiff Michael Koper and Plaintiff Brittany Koper
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were threatened with criminal prosecution, numerous civil lawsuits, and a loaded gun, all
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of which caused them to remain in the Presidents Conference Room against their will.
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47.
Plaintiff Michael Koper and Plaintiff Brittany Koper knew the Defendants
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had millions of dollars and several improper relationships with politicians and other
government officials to back up their threats.
48.
Plaintiff Michael Koper and Plaintiff Brittany Koper were fearful of these
threats by Defendants and did not feel they could leave the Presidents Conference Room.
In addition, Defendant Matthew Crouch threatening Plaintiff Michael Koper and Plaintiff
Brittany Koper with a loaded gun put them in fear that Defendant Matthew Crouch would
physically harm them.
49.
Based on information and belief, the actions of Defendants described above
constitute both assault and false imprisonment, and all took place in the Presidents
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Conference Room while Defendants were obtaining the sound recordings of Plaintiff
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Michael Koper and Plaintiff Brittany Kopers oral communications.
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50.
Based on information and belief, Defendants committed assault and false
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imprisonment, or directed each other to commit such, with the intent to capture the sound
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recordings of Plaintiff Michael Koper and Plaintiff Brittany Koper, so they are entitled to
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bring a civil action under Cal. Civ. Code 11708.8.

FOURTH CAUSE OF ACTION FOR CIVIL CONSPIRACY
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51.
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fully set forth herein, and this claim for civil conspiracy is asserted by Plaintiff Michael
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Koper and Plaintiff Brittany Koper against each of the Defendants.
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52.
Based on information and belief, each Defendant was aware that every other
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Defendant planned to intercept, disclose and intentionally use the confidential
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communications of Plaintiff Michael Koper and Plaintiff Brittany Koper.
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53.
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Defendant planned to use an electronic recording device to record the confidential
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communications of Plaintiff Michael Koper and Plaintiff Brittany Koper, without their
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consent.
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54.
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Defendant planned to commit assault and false imprisonment with the intent to capture
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the sound recordings of Plaintiff Michael Koper and Plaintiff Brittany Koper.
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That each Defendant agreed with every other Defendant and intended that
the above-described acts be committed.

PRAYER FOR RELIEF
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WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:
(1)
At least $75,000 in actual damages or more according to proof at trial;
(2)
Statutory damages according to proof at trial;
(3)
General and special damages according to proof at trial;
(4)
Punitive damages;
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(5)
Reasonable attorneys fees and other litigations costs;
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(6)
Interest according to law;
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(7)
Such other and further relief as this court may deem just and proper.
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DATED: January 29, 2015
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By: _________________________________
Michael W. Koper
Attorney for Plaintiffs Michael Koper and Brittany
Koper
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DEMAND FOR JURY TRIAL
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Michael W. Koper
Plaintiffs hereby demand a jury trial as provided by Rule 38(a) of the Federal
Rules of Civil Procedure.
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DATED: January 29, 2015
Michael W. Koper
By: _________________________________
Michael W. Koper
Attorney for Plaintiffs Michael Koper and Brittany
Koper
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Brittany and Michael Koper Lawsuit Against TBN

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Case 8:15-cv-00139-CJC-JCG Document 1 Filed 01/29/15 Page 1 of 11 Page ID #:1

Michael W. Koper (CA Bar No. 281422)

Attorney for Plaintiffs Michael Koper and Brittany Koper

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION

COMPLAINT FOR DAMAGES:

TRINITY CHRISTIAN CENTER OF

This Courts jurisdiction over the subject matter is predicated on 28 U.S.C.

This Courts jurisdiction over the subject matter is also predicated on 28

This Courts jurisdiction over the subject matter is also predicated on 28

Case 8:15-cv-00139-CJC-JCG Document 1 Filed 01/29/15 Page 2 of 11 Page ID #:2

in this judicial district and division. 28 U.S.C. 1391(a)(2). Moreover, there is no

this action is commenced. 28 U.S.C. 1391(a)(3).

business as Trinity Broadcasting Network (Defendant Trinity Broadcasting), is and was

Defendant International Christian Broadcasting, Inc., which also does

Defendant Matthew W. Crouch is and was at all times mentioned herein a

of Orange County, California.

Defendant Janice W. Crouch is and was at all times mentioned herein a

Orange County, California.

Case 8:15-cv-00139-CJC-JCG Document 1 Filed 01/29/15 Page 3 of 11 Page ID #:3

Unless otherwise alleged in this complaint, Plaintiffs are informed and

that agency and employment.

Defendant Trinity Broadcasting purports to be the worlds largest Christian

broadcasting network. Defendant Christian Broadcasting is a nonprofit corporation that

F. Crouch, Sr.s personal money.

Before she was terminated on or about September 30, 2011, Plaintiff

director of finance, corporate treasurer, and director of human resources. Plaintiff

controlled by the same board of directors.

Before he was terminated on or about September 30, 2011, Plaintiff Michael

directors. Plaintiff Michael Koper was a director of Christian Broadcasting.

Case 8:15-cv-00139-CJC-JCG Document 1 Filed 01/29/15 Page 4 of 11 Page ID #:4

Defendant Janice Crouch.

Defendant Trinity Broadcastings vice president of programming and a board member.

control of Defendant Trinity Broadcastings board of directors. Pursuant to Defendant

Trinity Broadcastings articles and bylaws, Defendant Trinity Broadcastings board of

directors is chosen solely by Defendant Trinity Broadcastings members. Circularly,

though, Defendant Trinity Broadcastings members are defined as and limited to

Defendant Trinity Broadcastings board of directors. The Crouches thereby elect

Broadcastings affairs as the companys only members/directors.

Defendant John Casoria is Defendant Trinity Broadcastings Assistant

purpose of maliciously prosecuting, harassing, and intimidating Plaintiff Michael Koper

Broadcasting, including unlawful distributions to Defendant Trinity Broadcastings

members and directors on the order of $100 million.

At the time she was terminated by Defendants on or about September 30,

Case 8:15-cv-00139-CJC-JCG Document 1 Filed 01/29/15 Page 5 of 11 Page ID #:5

Director of Finance, Corporate Treasurer, and Director of Human Resources.

At the time he was terminated by Defendants on or about September 30,

wrongfully terminated Plaintiffs employment in violation of the public policies of the

President, board of directors, to senior executive Defendant John Casoria, and to

Defendant Trinity Broadcastings IRS auditor.

Plaintiff Brittany Koper was promoted by Defendant Trinity Broadcastings

Broadcastings Corporate Treasurer on or about August 29, 2011.

Defendant Trinity Broadcastings Director of Human Resources.

In the weeks following Plaintiff Brittany Kopers promotion, Defendant

disclosed specific details concerning Defendant Trinity Broadcastings financial affairs to

Case 8:15-cv-00139-CJC-JCG Document 1 Filed 01/29/15 Page 6 of 11 Page ID #:6

to keep Defendant Trinity Broadcastings financial skeletons safely in the closet.

Plaintiff Brittany Koper learned through specific instructions from

Brittany Koper following her promotion.

The nature of these illegal activities involved the systematic diversion of

Defendant Trinity Broadcastings charitable assets through unlawful distributions to

Defendant Trinity Broadcastings directors through numerous channels. The magnitude

of these unlawful and related financial schemes uncovered by or disclosed to Plaintiff