Return Date: No return date scheduled Hearing Date: 9/23/2020 10:30 AM - 10:30 AM Courtroom Number: 2102 Location: District 1 Court FILED Cook County, IL 5/22/2020 7:34 PM IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS DOROTHY BROWN CHANCERY DIVISION CIRCUIT CLERK COOK COUNTY, IL 2020CH04310 GILBERT BILEZIKIAN, ) ) 9315805 Plaintiff, ) 2020CH04310 ) Case No. ______ v. ) ) SHOJI BOLDT, BARB BUTZ, JEFF CHOH, ) SILVIA ESCOBAR, JEFF MASON, MICHAEL ) ROTH, JOHN SLEETING, MARY SQUARE, ) and WILLOW CREEK COMMUNITY CHURCH, ) ) Defendants. ) FILED DATE: 5/22/2020 7:34 PM 2020CH04310 COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Now comes plaintiff Gilbert Bilezikian, by his attorneys, and for his complaint against defendants Willow Creek Community Church and each of its Elders, Shoji Boldt, Barb Butz, Jeff Choh, Silvia Escobar, Jeff Mason, Michael Roth, John Sleeting, and Mary Square, states as follows: Venue 1. Venue is proper because Cook County is a county in which the transaction or some part thereof occurred out of which the cause of action arose. Plaintiff 2. Plaintiff Gilbert Bilezikian is a resident of Du Page County, Illinois. Plaintiff is an American author, professor, lecturer, scholar and theologian on matters pertaining to Christianity including but not limited to gender equality. Due to his Th.D (Doctor of Theology), plaintiff is often referred to as “Dr. B”. He was born June 26, 1927. 3. Plaintiff earned his B.A. from the University of Paris, his M.Div. (Master of Divinity) from Gordon-Conwell Theological Seminary, and his Th.D. from Boston University. He also pursued a seven-year post-doctoral program at Ecole des Hautes Etudes at the Sorbonne in Paris. For 20 years, plaintiff was a professor of Biblical Studies at Wheaton College. He interrupted his tenure at Wheaton College to assume for three years the presidency of Haigazian University in Beirut, Lebanon, and to teach two years at Trinity College in Deerfield, Illinois. In 1981 and then again in 1992, the students, faculty and administration of Wheaton College awarded to plaintiff the distinction of Senior Teacher of the Year. 4. Plaintiff co-founded defendant Willow Creek Community Church (“Church”) with Bill Hybels (“Hybels”) in 1975. The Church is an American non-denominational and FILED DATE: 5/22/2020 7:34 PM 2020CH04310 multi-generational Evangelical Christian megachurch. Hybels became the first pastor of the Church. Plaintiff was a member of the original leadership team and among the first Elders of the Church. In 2000, Hybels was quoted by Christianity Today as stating "There would be no Willow Creek [Church] without Gilbert Bilezikian." In 2015 the Church staged a celebration to honor plaintiff under the banner "Dr. B Our Living Legend" at a packed and buoyant United Center in Chicago on the Church’s 40th anniversary. 5. In addition to numerous articles, plaintiff has published six books on matters pertaining to Christianity. They are: • Beyond Sex Roles: What the Bible Says about a Woman's Place in Church and Family (1985 1st Edition & 2nd Editions; 2006 3rd Edition; Baker Academic) • Christianity 101: Your Guide to Eight Basic Christian Beliefs (1993 Zondervan) • Community 101: Reclaiming the Local Church as Community of Oneness • How I Changed My Mind about Women in Leadership (a chapter in the compendium, 2010 Zondervan) • The Liberated Gospel: A Comparison of the Gospel of Mark and Greek Tragedy (1977 Baker; reprinted 2010 Wipf and Stock) • Eglise, Ouvre-Toi (i.e,. Church, Break Down Your Doors) (1980s’) 2 Plaintiff’s books and writings are quoted far and wide. At least four are still in print and sales thereof provide royalties to plaintiff: Beyond Sex Roles (now electronic only); Christianity 101; Community 101: Reclaiming The Local Church As Community; and The Liberated Gospel. 6. Plaintiff is frequently invited by Churches from different Christian denominations to speak, consult and meet to discuss matters concerning the Christian faith and practices, and for which plaintiff is often paid honoraria. 7. Plaintiff married Maria Lenart in 1957 and has been devoted and committed to her and to their marriage vows for 63 years. Plaintiff has always been a vocal critic of sexism FILED DATE: 5/22/2020 7:34 PM 2020CH04310 and misogyny, and an ardent advocate of gender equality and of adherence to marriage commitments. He was in the forefront advocating that the Bible teaches that women are co- equal with men. In 1985 he published Beyond Sex Roles: What the Bible Says about a Woman's Place in Church and Family. In 1988, he was one of several who drafted the statement, "Men, Women, and Biblical Equality," which laid out the biblical rationale for gender equality and was drafted in his dining room. In 2010 he contributed a chapter to the compendium How I Changed My Mind about Women in Leadership. Plaintiff’s advocacy of gender equality precipitated not just dissent from other scholars, etc., but hate mail as well. One dissenting biblical scholar, Wayne Grudem, was quoted as saying that “Beyond Sex Roles has regrettably been widely influential, Gilbert Bilezikian has been one of the three or four most influential egalitarian scholars." 8. In 2000, Christianity Today quoted Hybels as saying that without plaintiff, "There would be no Willow Creek—no small groups, no women in leadership, no passion for service." The publication added: “Not everyone at Willow Creek initially agreed with Bilezikian's position on women's ministry: among others, Hybels himself taught the traditional view of male headship. 3 After months of study and debate, the church decided that it would support women in any position of leadership—teacher, preacher, elder.” As a result of plaintiff’s advocacy, women came to and continue to occupy a significant part of the Church’s leadership. Indeed, four of the eight defendant Elders are women. The Defendant Church And Elders 9. Defendant Church is a non-profit corporation organized under the laws of the State of Illinois with its headquarters located in South Barrington, Cook County Illinois. The Church has several satellite locations for services in Cook County, Du Page County and FILED DATE: 5/22/2020 7:34 PM 2020CH04310 McHenry County. The South Barrington location sits on approximately 155 acres that include an auditorium with 7,095 seats, making it one of the largest auditoriums in the United States. The Church’s administrative offices are located in South Barrington and where its Board of Elders meet. 10. The Church is operated by a Board of eight Elders who serve as representatives of the Church and operate much as a board of directors, setting policy and the like for the Church. They are nominated and approved by the congregation. They are defendants Shoji Boldt, Barb Butz, Jeff Choh, Silvia Escobar, Jeff Mason, Michael Roth, John Sleeting, and Mary Square. Each of them signed the January 28, 2020 defamatory letter published on the Church’s website and later read aloud at the February 2, 2020 services and videotaped for YouTube as set forth below. Disagreement Between Plaintiff And Hybels--Plaintiff Stops Preaching At Church 11. When Pastor Hybels began managing the fast-growing Church like a Chief Executive Officer, a theological disagreement emerged between plaintiff and now Senior Pastor Hybels as to how the Church should be led and managed. As a result, in or around 2000, during 4 a discussion, Pastor Hybels told plaintiff that he should not preach at the Church any more. Although their relationship continued and did not break off, plaintiff chose not to preach at the Church again. Ann Lindberg 12. Ann Mitchell is an individual who first married as Ann Swezene and later remarried as Ann Lindberg (“Ms. Lindberg”). In recent years, Ms. Lindberg has made public statements on her turbulent life including the following in tweets or, on January 31, 2020, to journalist Julie Roys. She publicly stated that she has been “through a tremendous amount of FILED DATE: 5/22/2020 7:34 PM 2020CH04310 abuse from early childhood on” (January 31, 2020) and that she is “a survivor myself of more than one person in authority over me” (April 26, 2018). She has publicly stated that she had “a very abusive marriage” (January 31, 2020) with a “crazy scary ex” (July 31, 2018). She publicly stated that she has been “in therapy since 1987, plus 9 years of concurrent group therapy” (July 27, 2018). She publicly stated that she has PTSD (July 26, 2018). 13. Ms. Lindberg also publicly stated that “I can say that memory is a tricky thing. If one has been in counseling, which I have been for 31 years, some things thought about long enough can begin to feel true that aren't” (April 11, 2018). She further publicly stated that “We all tend to shade the truth for our benefit” (April 23, 2018). 14. One of plaintiff’s functions at the Church was to counsel those in need. Ms. Lindberg (then Ann Mitchell) attended services at the Church in the mid-1980’s, approached plaintiff and asked for his help in her situation of extreme need. She was struggling in the midst of difficult circumstances that included abuse, indigence and emotional issues. Plaintiff agreed to counsel her. While some improvement occurred as a result, plaintiff eventually noticed that she was becoming attached to him in unhealthy and inappropriate ways. As a result, plaintiff 5 referred Ms. Lindberg to professional counseling which she now had the resources to afford. Contact between plaintiff and Ms. Lindberg then came to an end. 15. Sometime later, some occasional and amicable communication between plaintiff and Ms. Lindberg resumed. Plaintiff frequently travelled for his work and would often send postcards of places visited to family and friends and that would include past and present students and mentees.