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

13. Defendant Trinity Broadcasting purports to be the world’s largest Christian broadcasting network. Defendant Christian Broadcasting is a nonprofit corporation that was formed by Defendant John Casoria and Paul F. Crouch, Sr. as a tax shelter for Paul F. Crouch, Sr.’s “personal money.”

14. Before she was terminated on or about September 30, 2011, Plaintiff Brittany Koper was Defendant Trinity Broadcasting’s chief financial officer (“CFO”), director of finance, corporate treasurer, and director of human resources. Plaintiff Brittany Koper was an officer and director of Christian Broadcasting, as well as the chief financial officer, director of finance, corporate treasurer, and director of human resources for numerous corporate entities affiliated with Defendant Trinity Broadcasting and controlled by the same board of directors.

15. Before he was terminated on or about September 30, 2011, Plaintiff Michael Koper was Defendant Trinity Broadcasting’s corporate secretary and vice president of media services. Plaintiff Michael Koper was also the corporate secretary for companies affiliated with Defendant Trinity Broadcasting and controlled by the same board of directors. Plaintiff Michael Koper was a director of Christian Broadcasting.

16. Plaintiff Michael Koper and Plaintiff Brittany Koper were husband and wife at all times mentioned in this Complaint. Plaintiff Brittany Koper’s maiden name is Brittany Crouch. She is the granddaughter of Paul Crouch Sr. and Defendant Janice Crouch, who were also husband and wife. Defendant Matthew Crouch is the son of Defendant Janice Crouch.

17. Paul Crouch Sr. is and was, at all time mentioned herein, Defendant Trinity Broadcasting’s founder, board member, president, and chief executive officer (“CEO”). Defendant Janice Crouch is and was, at all times mentioned herein, Defendant Trinity Broadcasting’s senior vice president and a board member. Defendant Matthew Crouch is Defendant Trinity Broadcasting’s vice president of programming and a board member.

18. Paul Crouch Sr., Defendant Janice Crouch, and Defendant Matthew Crouch maintained control over Defendant Trinity Broadcasting through exclusive and perpetual control of Defendant Trinity Broadcasting’s board of directors. Pursuant to Defendant Trinity Broadcasting’s articles and bylaws, Defendant Trinity Broadcasting’s board of directors is chosen solely by Defendant Trinity Broadcasting’s “members.” Circularly, though, Defendant Trinity Broadcasting’s “members” are defined as and limited to Defendant Trinity Broadcasting’s board of directors. The Crouches thereby elect themselves directors and maintain exclusive, perpetual control over Defendant Trinity Broadcasting’s affairs as the company’s only members/directors.

19. Defendant John Casoria is Defendant Trinity Broadcasting’s Assistant Secretary and General Counsel. He is also Defendant Janice Crouch’s nephew and is thereby Plaintiff Brittany Koper’s first cousin once removed. Plaintiffs are informed, believe, and based thereon allege that Defendant John Casoria is the director and senior manager of Redemption Strategies, and that this company was formed for the sole purpose of maliciously prosecuting, harassing, and intimidating Plaintiff Michael Koper and Plaintiff Brittany Koper (as well as members of Plaintiff Michael Koper’s family) in retaliation after the Kopers reported illegal conduct within Defendant Trinity Broadcasting, including unlawful distributions to Defendant Trinity Broadcasting’s members and directors on the order of $100 million.

GENERAL ALLEGATIONS

20. At the time she was terminated by Defendants on or about September 30, 2011, Plaintiff Brittany Koper had served as TBN’s 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 TBN’s 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 Defendant Trinity Broadcasting made unlawful by the laws of California and the United States and (b) reporting such unlawful conduct to Defendant Trinity Broadcasting’s President, board of directors, to senior executive Defendant John Casoria, and to Defendant Trinity Broadcasting’s IRS auditor.

23. Plaintiff Brittany Koper was promoted by Defendant Trinity Broadcasting’s board of directors as the company’s Chief Financial Officer (CFO) and Director of Finance on or about July 5, 2011, and she was appointed as Defendant Trinity Broadcasting’s Corporate Treasurer on or about August 29, 2011. Following her promotion, Plaintiff Brittany Koper also continued to serve in her prior job function as Defendant Trinity Broadcasting’s Director of Human Resources.

24. In the weeks following Plaintiff Brittany Koper’s promotion, Defendant Trinity Broadcasting’s board of directors and senior executive Defendant John Casoria disclosed specific details concerning Defendant Trinity Broadcasting’s financial affairs to Plaintiff Brittany Koper. Plaintiff Brittany Koper was also given full access to company records.

25. During these weeks, Plaintiff Brittany Koper learned from Defendant Trinity Broadcasting’s board of directors and Defendant John Casoria that Plaintiff Brittany Koper had been chosen for the promotion to Defendant Trinity Broadcasting’s head of finance because the directors needed somebody “within the family” that they could trust to keep Defendant Trinity Broadcasting’s 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 Koper’s 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 Broadcasting’s charitable assets through unlawful distributions to Defendant Trinity Broadcasting’s directors through numerous channels. The magnitude of these unlawful and related financial schemes uncovered by or disclosed to Plaintiff Brittany Koper is on the order of $100 million.

28. Plaintiff Brittany Koper and Plaintiff Michael Koper were terminated by Defendant Trinity Broadcasting because they refused to participate in the unlawful activities demanded by Defendant Trinity Broadcasting’s directors and senior executive Defendant John Casoria, and for making reports of those unlawful activities.

29. Plaintiff Michael Koper and Plaintiff Brittany Koper were specifically threatened and intimidated by Defendant Trinity Broadcasting’s directors and senior executive Defendant John Casoria when Plaintiff Michael Koper and Plaintiff Brittany Koper stated that these issues needed to be resolved and properly reported to state and federal officials. Plaintiff Michael Koper and Plaintiff Brittany Koper were told by Defendant Janice Crouch, Defendant Matthew Crouch, and Defendant John Casoria that they would have Plaintiff Michael Koper and Plaintiff Brittany Koper “arrested” and “prosecuted” if they tried to report Defendant Trinity Broadcasting or its directors for financial improprieties. Plaintiff Michael Koper and Plaintiff Brittany Koper were advised by Defendant John Casoria that they, too, had broken the same laws and that they were “prohibited” as “accomplices” from reporting alleged crimes outside the company. Plaintiff Michael Koper and Plaintiff Brittany Koper were told that they were required to go through Defendant Trinity Broadcasting’s attorneys, only, if they had concerns. And, 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 during this isolation that Defendant Trinity Broadcasting’s board of directors announced that Plaintiff Michael Koper, Plaintiff Brittany Koper, and her father Paul Crouch, Jr. were all fired. When questioned about the termination, Defendant Matthew Crouch began tapping the firearm he had brought to the meeting and asked Plaintiff Brittany Koper what she thought would happen when she wrote a memo to the board critical of Defendant Matthew Crouch’s financial improprieties. Defendant Matthew Crouch continued tapping the gun he was holding to ensure that Plaintiff Brittany Koper recognized the lethal threat being made.

31. On January 29, 2014 Plaintiff Michael Koper and Plaintiff Brittany Koper discovered, for the first time, that multiple confidential communications they had with Paul Crouch, Sr., Defendant Matthew Crouch, and/or Defendant John Casoria were recorded by Defendants using an electronic recording device, and that these recordings had subsequently been edited and manipulated by Defendants. Defendants then disclosed and intentionally used these intercepted communications on multiple occasions.

FIRST CAUSE OF ACTION UNDER USCA § 2520

32. Paragraphs 1-31 of this complaint are incorporated by reference as though fully set forth herein, and this claim under U.S.C.A. § 2520 for violation of U.S.C.A. § 2511 is asserted by Plaintiff Michael Koper and Plaintiff Brittany Koper against each of the Defendants.