Weems Lawsuit Vs Association of Related Churches

Case 3:23-cv-00811-MMH-LLL Document 1 Filed 07/12/23 Page 1 of 42 PageID 1
UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION
CHARLES S. WEEMS, IV, an individual,

KERRI WEEMS, an individual,
and CELEBRATION
GLOBAL, INC., a Florida not for profit Case No.:
corporation, HONEY LAKE FARMS,
INC., a Florida not for profit corporation,
NORTHSTREAM MANAGEMENT
GROUP, LLC, a Florida limited liability
company, and WEEMS GROUP, LLC,
a Florida limited liability company,
Plaintiffs,
v.
ASSOCIATION OF RELATED CHURCHES,

a Texas not-for-profit corporation,
CHRIS HODGES, individually,
DINO RIZZO, individually, and
JOHN SEIBELING, individually,
Defendants.
/
COMPLAINT & DEMAND FOR JURY TRIAL
Plaintiffs, Charles Stovall Weems, IV (“Pastor Weems”), Kerri Weems (“K.
Weems”), Celebration Global, Inc. (“Celebration Global”), Honey Lake Farms, Inc.
(“Honey Lake Farms”), NorthStream Management Group, LLC (“NorthStream”),
and Weems Group, LLC (“Weems Group”), sue Defendants, Association of Related
Churches (“ARC”), Chris Hodges (“Hodges”), Dino Rizzo (“Rizzo”), and John
Seibeling (“Seibeling”), and allege as follows:

OVERVIEW OF THE CASE
1. This case arises out of a continuing unlawful conspiracy masterminded
by the Defendants to protect and expand their church growth business interests and
endeavors and the substantial income they generate by destroying Plaintiffs and
eliminating them as perceived threats and competitors, which included engineering a
takeover at Celebration Church of Jacksonville, Inc. (“Celebration Church”) to allow
Defendants to effectively gain control over its operations and substantial assets, cover-
up numerous criminal and tortious acts committed in the process, and frame the
Weemses’s for financial crimes they never committed.
2. Defendants were consumed by greed and the desire to advance their own
financial and business interests when they deliberately targeted Pastor Weems and
those closest to him because he rejected their unbridled church growth model and was
focused on missionary work and developing supporting businesses that Defendants
perceived as a significant threat to their economic interests.
3. Using ARC’s significant influence and power as a vehicle to facilitate and
conceal their nefarious scheme, Defendants intentionally caused substantial financial
and other irreparable harm to the Plaintiffs through a pattern of unlawful and often
criminal acts that included extortion, bribery, psychological abuse, wire fraud, and
computer crimes which ultimately caused over $100 million in damages.
4. This action seeks to hold Defendants accountable for their illegal and
tortious misconduct and put a stop to the substantial harm their unlawful actions
continue to cause.
2
PARTIES, JURISDICTION, AND VENUE
5. This is an action for damages well in excess of $75,000.00, exclusive of
interest, costs, and attorneys’ fees, as well as equitable relief.
6. Plaintiff, Pastor Weems, is a resident and citizen of Duval County,
Florida.
7. Plaintiff, K. Weems, is a resident and citizen of Duval County, Florida.
8. Plaintiff, Celebration Global, is a Florida not for profit corporation with
its principal place of business located at 2627 Belfort Road, Jacksonville, Florida
32216.
9. Plaintiff, Honey Lake Farms, is a Florida not for profit corporation with
its principal place of business located at 2627 Belfort Road, Jacksonville, Florida
32216.
10. Plaintiff, NorthStream, is a Florida limited liability company with its
principal place of business located at 2627 Belfort Road, Jacksonville, Florida 32216,
whose sole members are Pastor Weems and K. Weems.
11. Plaintiff, Weems Group, is a Florida limited liability company with its
principal place of business located at 2627 Belfort Road, Jacksonville, Florida 32216,
whose sole members are Pastor Weems and K. Weems.
12. Defendant, ARC, is a Texas not-for-profit corporation with its principal
place of business located at 1201 Lee Branch Lane, Birmingham, AL 35242.
13. Defendant, Hodges, is a resident and citizen of Birmingham, Alabama.
14. Defendant, Rizzo, is a resident and citizen of Birmingham, Alabama.
3
15. Defendant, Seibeling, is a resident and citizen of Memphis, Tennessee.
16. Non-party, Celebration Church, is a Florida not-for-profit corporation
with its principal place of business at 9555 R.G. Skinner Parkway, Jacksonville,
Florida 32256.
17. This Court has subject matter jurisdiction over this action pursuant to
28 U.S.C. §1332 because it involves claims between citizens of different states with an
amount in controversy that exceeds the sum of $75,000.00, exclusive of interest and
costs.
18. Pursuant to 28 U.S.C. §1391, venue is proper in this District because a
substantial part of the events and omissions giving rise to the claims alleged herein
occurred in this District.
19. Defendants, directly and/or through employees, agents, authorized
representatives, co-conspirators, subsidiaries, affiliates, and/or other persons, entities,
and/or representatives acting under their management, direction, supervision, and/or
control, engaged in numerous contacts in, with, and/or directed at the state of Florida
upon which this action is based.
20. Defendants knowingly and intentionally entered into one or more
contracts or agreements, pursuant to which they, directly and/or through employees,
agents, authorized representatives, co-conspirators, subsidiaries, affiliates, and/or
other persons, entities, and/or representatives acting under their management,
direction, supervision, and/or control, committed and engaged in tortious and overt
acts within and directed at the state of Florida.
4
21. Based on the facts alleged throughout this Complaint, this Court has
personal jurisdiction over each Defendant under Section 48.193, Florida Statutes,
because they each personally, directly, in concert with one another, and/or through
an employee, agent, co-conspirator, subsidiary, affiliate, and/or other person or entity
acting under their management, supervision, direction, and/or control, engaged in one
or more of the following acts:
a. committing tortious acts within the state of Florida;
b. committing intentional torts expressly aimed at Florida,

effects of which were suffered in Florida;
c. operating, conducting, engaging in, or carrying on a

business or business venture within the state of Florida, or
having an office in Florida;
d. engaging in substantial and not isolated activity within the

state of Florida; and/or
e. engaging in a conspiracy to commit tortious acts against

Plaintiffs within the state of Florida and engaging in overt
acts in furtherance of that conspiracy within or directed at
the state of Florida.
22. Based on the facts alleged throughout this Complaint, sufficient
minimum contacts exist between each Defendant and the state of Florida to satisfy
Due Process under the United States Constitution because Defendants: (1) engaged
in substantial and not isolated activity within and directed at the state of Florida;
(2) conducted business through employees, agents, co-conspirators, and/or authorized
representatives located in the state of Florida; and/or (3) committed and conspired to
commit intentional torts expressly aimed at Florida, the effects and harms of which
were calculated to and did cause injury within the state of Florida. Accordingly, each
5
of the Defendants could and should have reasonably anticipated being sued for the
claims alleged herein in the state of Florida.
23. At all times material to this action, Defendants were the agents, licensees,
employees, partners, joint-venturers, co-conspirators, masters, and/or employers of
one another, and each of them acted within the course and scope of an agency, license,
partnership, employment, conspiracy, ownership, joint venture, or contractual
relationship with one another. At all times material to this action, each Defendant’s
acts, omissions, and misconduct alleged herein were known to, authorized, approved,
and/or ratified by the other Defendants; and/or Defendants engaged in such acts,
omissions, and misconduct in concert or active participation with one another or to
aid or abet one another.
24. Defendants conspired and agreed with each other and others to engage
in unlawful and tortious conduct intended to harm and injure Plaintiffs, in furtherance
of which Defendants and their agents and co-conspirators engaged in overt acts within
and directed at the state of Florida and could and should have reasonably anticipated
that the acts and omissions alleged herein connected them to Florida in a meaningful
way.
25. Defendants’ actions and misconduct alleged herein produced and/or
substantially contributed to producing the damages, injuries, and harms Plaintiffs
suffered, and for which they seek recovery and redress through this action; which
injuries and harms occurred in the state of Florida and the greatest effects of which
were suffered within the state of Florida.
6
26. All conditions precedent to the filing and maintenance of this action
have occurred, have been performed, and/or have been waived.
COMMON FACTUAL ALLEGATIONS TO ALL COUNTS
Overview of the Plaintiffs
27. Pastor Weems and K. Weems founded Celebration Church in 1998 and
devoted over 23 years of their lives to their church, its congregation, and its missions.
28. Initially, Celebration Church was comprised of a single site in
Jacksonville, Florida, but through years of dedication and sacrifice Pastor Weems and
K. Weems grew that single site into a global, multi-site, non-denominational church
with nearly 20,000 members.
29. Pastor Weems served as Celebration Church’s Senior Pastor, CEO, and
President from its inception until he was forced to resign and separate himself and his
family from the church on April 15, 2022.
30. As Senior Pastor of Celebration Church, Pastor Weems had sole
authority to set and shape the vision and direction of Celebration Church, and his
responsibilities included: (1) complete plenary authority, control, and responsibility
for directing missions and spiritual activities of the church; (2) serving as President and
Chief Executive Officer of the church and having authority to direct all of its day-to-
day operations, including establishing budgets, raising funds, and directing monies;
and (3) acting as Chairman of the Board.
7
31. Celebration Church’s Board of Trustees were nominated exclusively by
the Senior Pastor for one calendar-year terms and responsible for management and
oversight of its corporate matters and financial resources.
32. Celebration Church’s “Overseers” were nominated by the Senior Pastor
and confirmed by the Board of Trustees, provided apostolic oversight to the Senior
Pastor, and were charged with protecting the Church through counsel, prayer, and if
required, the investigation and discipline of the Senior Pastor.
The Weemses’s Anti-Growth Vision and Missionary Work
33. In 2018, Pastor Weems came to the realization that Celebration Church
had become too “corporate” and focused on generating attendance and revenue and
needed to concentrate on helping the poor, missionary work, equality, and simplifying
the church by creating alternative revenue streams that would make the church less
donation dependent.
34. Pastor Weems also came to recognize that the modern church growth
system and its constant pressure to grow attendance and generate more and more
revenue to keep the corporate “machine” running was having significant negative
psychological and health impacts on pastors, who needed counseling, guidance, and
treatment to recover from the adverse effects of the growth model that Defendants are
at the forefront of promoting.
35. To execute his new vision, Pastor Weems and K. Weems developed a
plan that included establishing several corporate entities that collectively would house
and fund Celebration Church’s significant administrative and personnel operations,
8
quickly reduce expenses and Celebration Church’s debt, and operate and fund the
missionary work on which Pastor Weems wanted to focus.
36. The plan for this vision included the following:
A. a retreat and outpatient facility for pastoral care—Honey

Lake Farms—and an adjoining medical clinic—Honey
Lake Clinic, Inc.—that would provide Christian mental
health treatment services, the revenue from which would be
used to build out and support Honey Lake Farms’ mission;
B. a for profit corporation—NorthStream—designed to

provide centralized and shared management services to
Celebration Church and numerous other churches that
enabled church leadership to focus their attention on
ministry and missions rather than operational aspects of
their churches; that would also develop Restorative
Community Developments (RCD’s1), the first of which was
Honey Lake Farms; and
C. a separate entity—AWKNG, Inc.—which would act as a

hub for the restorative/ministry programing used at Honey
Lake Farms, a theology school, missionary partnerships,
media operations, and other similar endeavors.
37. Celebration Global was designed to be the umbrella organization under
which Pastor Weemses’s missionary work would be housed.
38. As they began implementing their anti-growth, missionary focused
vision, Pastor Weems and K. Weems contributed their own personal money and
invested in Weems Group for a combined total of approximately $1.2 million that was
used to fund the operations of Honey Lake Farms, NorthStream, and AWKNG.
1
Restorative Community Developments are self-contained investment portfolios ideal for
venture philanthropists and impact investors, combining profitability with socially and
environmentally conscious that directly impact human flourishing in both rural and urban
areas.
9
Overview of Defendants
39. ARC is a cooperative of independent churches from different
denominations, networks, and backgrounds, the members of which consist of
(a) churches “planted” or launched through ARC and (b) churches that invest in the
mission of ARC financially.
40. Although ARC started as a loosely connected group of people who
wanted to help smaller churches, it eventually (under the leadership of Hodges) shifted
its focus to generating large attendance growth and church “planting” to vastly expand
Defendants’ influence and revenue streams.
41. ARC has become one of the largest church planting organizations in
North America and has planted more than a thousand churches since 2000.
42. ARC-planted churches enter into contractual agreements with ARC that,
among other things, provide for initial loans to launch the church and require the
church to pay 10% of tithes and offerings to ARC until this loan is repaid; following
which the church is required to send ARC an ongoing amount of 2% of its monthly
tithes/offerings.
43. Celebration Church is not an ARC-planted church, and at all times
material to this action had no legal, contractual, or financial obligations to ARC or
any of the other Defendants.
44. Historically, Celebration Church gratuitously donated approximately
$150,000 to $200,000 per year to or for the benefit of ARC’s church planting
operations. However, Defendants were constantly pressuring Pastor Weems to
10
commit to donating 2% of Celebration Church’s income to ARC for church planting
purposes.
45. ARC is not a denomination and claims that it does not issue directives
on what its member churches should promote doctrinally, philosophically,
ministerially, or politically; and further claims that all of its member churches are
completely and totally autonomous—operationally, financially, and governmentally.2
46. ARC has attained a significant amount of power and influence through
its church growth model and church-planting operations, and is able to maintain and
expand such power and influence through affiliated entities and “partners” that it
heavily encourages its members to use.
47. Hodges is one of the co-founders of ARC and Founder and Senior Pastor
of Church of the Highlands (“Highlands”), one of the largest churches in the United
States with over 60,000 members and 23 campuses.
48. Hodges fully embraces the modern church growth model and has vocally
expressed his goal to help 1,000 churches break the 1,000-attendance barrier.
49. Hodges founded and operates several entities closely affiliated with ARC
and Highlands that are heavily promoted as ARC “partners,” including GrowLeader,
LLC (“GrowLeader”) and Highlands College.
50. GrowLeader is a for-profit company that is closely affiliated with and
heavily promoted through ARC that generates significant revenue and resulting
2
https://www.arcchurches.com/about/our-structure/
11
financial benefits to Defendants by providing fee-based mentoring, coaching, training,
and consulting services and related resources focused on promoting and advancing the
modern church growth system to churches and their leadership.
51. Hodges derives significant power and financial benefits from the
promotion and advancement of GrowLeader and Highlands through ARC.
52. Rizzo is the Executive Director of ARC and an Associate Pastor at
Church of the Highlands3 who also served as an Overseer at Celebration Church until
September 2021.
53. Seibeling is a Founder and Senior Pastor of The Life Church and
founding board member of ARC who also served as an Overseer at Celebration
Church until September 2021.
54. Promoting the use of ARC attorneys by churches is one means through
which Defendants furtively maintain control and oversight over ARC members.
55. Attorneys David Middlebrook and Steven Goodspeed (“Middlebrook
Goodspeed”) specialize in the areas of church formation, governance, operations, and
taxes. At all times material to this action, Middlebrook Goodspeed were law partners
whose firm was promoted as an ARC “partner,” and they contemporaneously
represented ARC and Celebration Church, as well as numerous other ARC member
churches.
3
https://jamesriver.church/author/drizzo
12
56. Middlebrook’s current law firm, The Church Lawyers Group, is a
featured ARC “partner” that provides special resources for ARC members.
57. Middlebrook Goodspeed prepared Celebration Church’s governing
Bylaws installed in 2015.
58. Attorneys Lee Wedekind (“Wedekind”) and Kristin Ahr (“Ahr”) work
for the Nelson Mullins Riley & Scarborough LLP law firm (“Nelson Mullins”) and
have served as litigation counsel for ARC and Rizzo. At all times material to this
action, Wedekind and Ahr, through Nelson Mullins, represented ARC; including
when they purportedly represented Celebration Church during the events described
below.
59. At all times material to this action, Defendants acted as the principals of
and directed and controlled the acts and conduct of Middlebrook Goodspeed and
Wedekind and Ahr upon which the claims set forth herein are based; during the
performance of which Middlebrook Goodspeed and Wedekind and Ahr were acting
in the capacity as Defendants’ undisclosed agents carrying out Defendants’ directives
under Defendants’ control.
The Implementation of Weemses’s New Vision & Direction for Celebration
60. In 2019, Pastor Weems and K. Weems began working toward
implementing Pastor Weems’s new vision and direction for Celebration Church and
transitioning Pastor Weems from Celebration Church’s Senior Pastor to a Founding
Pastor role in which he would be able to spend much more of his time and energy on
13
missions and less on the church’s day-to-day operations, while also continuing to have
an ongoing relationship with the congregation he founded and pastored.
61. Pastor Weemses’s vision to shift Celebration Church’s focus away from
growth and toward missionary work is antithetical to Defendants’ church growth
business and operational model and financial interests.
62. As Pastor Weems began to implement his new shift in focus, he informed
Defendants that Celebration Church would only be willing to donate funds to ARC if
they were earmarked for missionary work and helping pastors get the counseling,
guidance, and treatment they needed to shift their focus to ministry and missions,
rather than church growth; while also expressing his concerns over the ARC system
and its focus on planting churches to help expand ARC and GrowLeader and
Defendants’ own personal interests, causing stress and psychological harm for pastors.
63. Middlebrook Goodspeed consulted Pastor Weems and Celebration
Church on his transition to the Founding Pastor role and the memorialization of
agreed upon terms and conditions of a Founding Pastor agreement, retirement
package for Pastor Weems and K. Weems, parsonage, and continued and ongoing
financial support for the missions in which Pastor Weems was involved.
64. Celebration Church’s Board of Trustees and Overseers were fully aware
of, approved, and agreed on behalf of Celebration Church to the terms, conditions,
and agreements associated with Pastor Weemses’s transition to Founding Pastor, the
Weemses’s’ retirement package, their parsonage, and the commitment to provide
financial support for the missions with which Pastor Weems would be involved.
14
65. Attendant to his transition to Founding Pastor, Pastor Weems was also
working on identifying someone as a potential eventual successor to the Celebration
Church Senior Pastor position.
66. Defendants were aware of this and seized on it as an opportunity to oust
Pastor Weems from Celebration Church and plant an ARC-affiliated pastor they knew
they could control and who would continue to advance Defendants’ church growth
model.
67. Defendants identified ARC agent Tim Timberlake (“Timberlake”) as the
perfect candidate to fill this role, and Rizzo subsequently vouched for Timberlake to
Pastor Weems.
68. At all times material to this action, Defendants acted as the principals of,
directed, and controlled acts and conduct of Timberlake upon which the claims set
forth herein are based; during the performance of which Timberlake acted in the
capacity as Defendants’ undisclosed agent carrying out Defendants’ directives under
Defendants’ control.
69. Unaware of the clandestine agency relationship between Defendants and
Timberlake and Defendants’ planting of Timberlake to advance their conspiracy
against Plaintiffs, Pastor Weems moved forward with the Founding Pastor transition
plan, pursuant to which Timberlake initially would serve as lead pastor at Celebration
Church’s Jacksonville campus while Pastor Weems retained legal control and
authority as the Senior Pastor, President, CEO, and Chairman of the Board. Pastor
Weems would coach Timberlake through his development plan while observing his
15
performance and simultaneously working to memorialize the agreed upon terms of his
transition to Founding Pastor.
70. In December 2019, Celebration Church’s Compensation Committee
(including Seibeling and Rizzo) approved a compensation package that included
(among other things) Celebration Church’s acquisition of a parsonage for the
Weemses’s and the payment of $100,000 per year to Pastor Weems until age 65; the
terms of which were memorialized in a Compensation Resolution fully executed and
approved by the Board of Trustees.
71. On December 20, 2019, Celebration Church entered into a Parsonage Use
License Agreement with Pastor Weems and K. Weems, effective as of January 10, 2020.
72. Based on the agreements memorialized in the Compensation Resolution
and the rights that accrued to Pastor Weems and K. Weems by virtue of the benefits
Celebration Church agreed to provide, the Weemses’s sold their home and moved into
a temporary parsonage.
73. During the same time period, Timberlake abruptly moved to Jacksonville
without prior notice to Pastor Weems, 11 months ahead of the agreed upon schedule,
and immediately began exerting pressure on Pastor Weems to hand over control of
Celebration Church.
74. In early 2020, as a result of the COVID pandemic and lockdowns,
Celebration Church was limited to video services until September 2020. During this
difficult time, Pastor Weems and K. Weems were instrumental in helping the church
navigate through the financial difficulties caused by COVID and lockdowns and other
16
operational problems created by certain executive leadership under the control of Lisa
Stewart (“Stewart”), Celebration Church’s CFO at that time.
75. When in-person services finally resumed, Timberlake started leading
Sunday morning services at Celebration Church’s Jacksonville campus and Pastor
Weems focused on mission work, reaching more of the church’s members across the
country and world through video, refining the organization of the church and its
missions and related organizations, and working with Middlebrook Goodspeed to
memorialize Celebration Church’s agreements concerning Pastor Weems’s transition
to Founding Pastor.
76. One of Pastor Weems’s and K. Weems’s primary focuses during this time
was Honey Lake Farms.
77. In her role as CFO of Celebration Church at that time, Stewart also
served as CFO of Honey Lake Farms and Honey Lake Clinic.
78. Around this time, Celebration Church and Kevin Cormier (“Cormier”)
entered into a collaboration whereby construction-type entities owned by Cormier
were hired by Celebration Church to perform land and housing improvements and
management services at Honey Lake Farms. Not long thereafter, Cormier promised
to donate $1 million of in-kind construction-type services at Honey Lake Farms.
79. Throughout 2020, construction work and land management services
were performed at Honey Lake Farms by Cormier’s companies, which Pastor Weems
was led to believe was part of Cormier’s $1 million pledge. Pastor Weems expected
17
that Stewart was properly accounting for this donation and responsibly managing the
church’s finances in accordance with her fiduciary duties.
80. In December of 2020, the Honey Lake Farms Lodge opened and started
offering retreats and its outpatient facility for pastoral care.
81. Honey Lake Clinic also began generating revenue providing Christian
mental health treatment services.
82. Pastor Weems soon appointed Cormier as a Celebration Church Trustee
and Stewart left her position as Celebration Church CFO and transitioned to work
solely for Honey Lake Clinic as its CEO.
83. During her time working as CFO for Celebration Church and Honey
Lake Clinic, Stewart gave false financial reports to Pastor Weems, which
misrepresented balances in the church’s accounts, and engaged in additional
fraudulent misconduct.
84. For example, in 2020 Stewart refused to separate the AWKNG mission
organization as a separate 501(c)(3) entity distinct from the church and concealed her
insubordination to Pastor Weemses’s and the Board of Trustees’ directives to separate
the funds designated for the AWKNG organization into a separate account from that
of the church. By doing this, she was able to hide her financial and operational
mismanagement and retain control of funds to create inaccurate and misleading
reports in which Stewart materially misrepresented the church’s unrestricted cash as
$2.2 million more than it actually was. This and other fraudulent acts were
documented in Celebration Church’s 2020 audit.
18
85. Stewart also provided Cormier with unrestricted access to Honey Lake
Farms’ bank accounts and failed to supervise his activities. Pastor Weems had no
access to view these accounts, which Cormier used to reimburse his companies for
expenses without any oversight or accountability.
86. Pastor Weems eventually discovered and verified that Cormier had
embezzled church funds, engaged in a fraudulent billing scheme, and attempted to
commit usury.
87. Stewart knew that Cormier had not donated any of the $1 million in work
that he pledged and that the work for which he was billing the church was actually
supposed to be “donated” (i.e., free), but allowed payments to be issued to Cormier’s
entities knowing that no agreements were in place to support them and that no
authorization or approvals were obtained for the work allegedly performed. Cormier
also stopped submitting any substantiation for his invoices but continued to get
payments.
88. In April of 2021, Pastor Weems confronted Cormier about his above-
described misconduct and Cormier admitted that he reneged on his pledge to donate
$1 million of in-kind services and sought to remedy the situation by “donating” the
work he claimed to have performed but for which he had not yet been paid, along with
a house that the church had been renting from him.
89. Meanwhile, Pastor Weems and K. Weems continued working tirelessly
to bring stability, structure, consistency, and clarity to Celebration Church’s staff,
congregation, and organization, and to greatly improve the church’s financial position.
19
They believed everything was moving forward as planned with the transition to Pastor
Weemses’s role as Founding Pastor and the church’s related agreements concerning
the Weemses’s’ retirement packages, funding for Celebration Global, and the
parsonage.
90. In May of 2021, the Weemses’s and Celebration Church agreed on the
property that would be the Weemses’s’ permanent parsonage and it was sold to the
Church for that purpose—following which Celebration Church agreed to and did treat
that property as the Weemses’s' parsonage under the Parsonage Use License Agreement.
91. The Board of Trustees also represented that they were working with
Middlebrook Goodspeed on finalizing written documents (such as a Founding Pastor
Emeritus Operating Agreement) memorializing the terms that Celebration Church
already verbally agreed upon and approved concerning Pastor Weems’s transition to
Founding Pastor, the Weemses’s’ retirement compensation, the parsonage, and the
funding of the missions with which Pastor Weems is involved.
92. Defendants all were aware of the agreements Celebration Church made
and approved concerning Pastor Weems’s transition to Founding Pastor, the
Weemses’s’ retirement compensation, the parsonage, and the funding to be provided
to Celebration Global for the missions with which Pastor Weems is involved.
93. However, unbeknownst to Pastor Weems, Defendants and their agents
were already working behind the scenes for quite some time on a plan to oust Pastor
Weems from his leadership position and interfere with Plaintiffs’ agreements with
Celebration Church.
20
94. Among other things, this included: the planting of Timberlake and
direction and approval of his subversive acts described below; enlisting Timberlake
and Cormier to help oust Pastor Weems; enlisting Stewart to manufacture evidence of
supposed financial crimes and mismanagement to use against the Weemses’s; and
enlisting Gaby Sullivan (K. Weems’s assistant and an employee of NorthStream) to
illegally access and download K. Weemses’s private data, emails, medical
information, and therapy sessions and provide them to Defendants to use against the
Weemses’s. Sullivan told multiple Celebration Church staff members that she was
“protected” and that Celebration Church was going to be taken over.
95. In September 2021, Hodge’s Highlands church announced that it was
spending $4.5 million to build its own “Lodge Retreat Center”—a center for pastoral
counseling reported as being “the vision of” Hodges and Rizzo4 that was virtually
identical to the Honey Lake Farms’ Lodge that had been up and running since
December 2020. Around the same time, Rizzo and Seibeling stepped down as
Celebration Church Overseers.
96. Honey Lake Farms’ Lodge and The Lodge Retreat Center (once
completed) would have been competitors. However, Defendants knew Honey Lake
Farms’ Lodge had a significant advantage because it was already operational and had
numerous retreats, counseling and restorative programs led by professional therapists
4
https://ministrywatch.com/church-of-the-highlands-quietly-advances-controversial-
pastoral-retreat-center/
21
and able to provide outpatient clinical care through its association with Honey Lake
Clinic, which Defendants’ “Lodge” was unable to provide.
97. Defendants also perceived Honey Lake Farms as a threat because it was
providing counseling services that included programs designed to improve pastoral
mental health by moving away from the church growth model.
98. During this same time period, Pastor Weems uncovered more evidence
of Cormier embezzling money from Celebration Church.
99. On September 22, 2021, Pastor Weems informed Rizzo and Seibeling
about Cormier’s embezzlement and fraud and resulting need to dismiss him from the
Celebration Church board. To Pastor Weems’s surprise, they revealed that Cormier
called them back in April of 2021 (10-days after Pastor Weems first confronted
Cormier about his financial misconduct) and asked them to initiate an investigation
against Pastor Weems.
100. In October of 2021, the Weemses’s continued to move forward with their
transition plan and missionary work, meeting and developing an advantageous
business relationship with Historical Concepts, a highly respected architecture and
development firm in Atlanta, and commissioned (at a cost over $14,000) the rendering
of a master site plan for Honey Lake Farms so that they could begin recruiting
investors for the RCD portion of the project.
101. The Weemses’s immediately drove from their meeting with Historical
Concepts to the 2021 ARC conference at Seacoast Church in South Carolina to
22
demonstrate their goodwill toward their friends at ARC and put forth the idea of
working together around missions.
102. As a result, Pastor Weems and Greg Surratt agreed to partner to expand
the availability of pastoral health retreats by hosting them at Honey Lake Farms and
Surratt’s lodge, which would have generated an estimated $1.5 million in income for
Honey Lake Farms and AWKNG over the next 24 months.
103. Not long thereafter, AWKNG and Honey Lake Farms held a fundraiser
to raise money for scholarships for pastors and ministers to attend wellness retreats,
which raised approximately $250,000 and connected Plaintiffs with Willie Robertson
(well known for the “Duck Dynasty” reality show). Robertson expressed interest in
partnering with Honey Lake Farms and even shot some episodes of his series, “Buck
Commander,” at the farm. During the fundraising event, discussions were had with
Robertson around potential future filming and other types of partnerships around
youth programs and community evangelism at Honey Lake Farms.
104. In addition to Robertson, Honey Lake Farms was poised to partner with
Wildwood Ranch, Hand of Hope, and Convoy of Hope on very profitable and
beneficial endeavors for Honey Lake farm’s mission.
105. NorthStream had also secured an advantageous business relationship
with the city of Greenville, FL related to its first RCD and was launching its first RCD
in Africa through Project Africa in Zimbabwe.
23
106. Plaintiffs had also developed an advantageous business relationship with
David Maura through which they were poised to secure significant investments in their
operations at Honey Lake Farms and NorthStream.
The Implementation of the Plan to Destroy Plaintiffs

and Frame Pastor Weems and K. Weems for Financial Crimes
107. In November of 2021, Pastor Weems approached the Honey Lake Clinic
board about releasing disbursements to Honey Lake Farms in compliance with the
clinic’s bylaws. Although strongly opposed by Stewart and Honey Lake Clinic CFO,
Devan Schandig, the board voted unanimously in favor of the disbursement.
108. Soon thereafter, Defendants began to execute the final phase of their plan
to destroy Plaintiffs.
109. Unbeknownst to Pastor Weems, Rizzo and Timberlake contacted Surratt
and informed him that Pastor Weems was about to be put under investigation by
Cormier, Powell, and Rowe and that Surratt should cut all ties with Pastor Weems
and Honey Lake Farms, which led to Surratt to immediately call Pastor Weems and
cancel the projects they had planned to partner in together.
110. Heading into a December 2021 Celebration Church Board of Trustees
meeting, the Weemses’s were completely in the dark about the plot against them and
believed the Board of Trustees was set to give final approval the written documents
memorializing the existing agreements with Celebration Church.
111. Instead, acting under the influence and control of Defendants and their
agents, the Trustees abruptly changed course at the December 8, 2021 meeting;
24
producing a draft Founding Pastor Emeritus Agreement with substantially different terms
than those that had already been agreed upon by Celebration Church (most notably,
termination provisions that would allow the Trustees to deny the Weemses’s the
rights and benefits Celebration Church had already agreed to provide), and slashing
the already agreed upon funding promised by Celebration Church to Celebration
Global by fifty percent (approximately $24 million over 15 years).
112. This drastic reduction in missions funding combined with the campaign
targeting Plaintiffs’ strategic partnerships all but assured the failure of the mission
organizations and operations in which the Weemses’s had already personally
invested.
113. Defendants continued to secure Timberlake’s allegiance to their cause,
curate his image, and promote him as a capable leader for Celebration Church by
orchestrating hundreds of thousands of dollars in monetary payments to him directly
and indirectly through his ministry for book sales and promotion, in exchange for
which and at Defendants’ direction, Timberlake relentlessly contacted pastors,
missional partners, strategic partners, leaders of church networks, and donors; telling
them that Pastor Weems was about to be investigated for financial misconduct and
would be removed as Senior Pastor, leaving Timberlake in control of the church, and
that they should deal solely with him since Pastor Weems would be ousted with no
possibility of return. Timberlake even directed Celebration Church youth pastors to
begin telling the youth that Pastor Weems was under investigation for financial
25
misconduct—leading several of them, some as young as 12, to be confused and talk
to their parents about this.
114. Timberlake also made it clear that he would take Pastor Weems’s place
at ARC and return Celebration Church’s vision and direction to ARC’s and
GrowLeader’s church growth model.
115. Defendants also committed to ruining the Plaintiffs’ reputations,
specifically in the ministry world, so they could never be in ministry or make a living
and have no possible way of ever being part of Celebration Church again.
116. Pastor Weems was planning on dismissing Cormier at the end of the year
and had enlisted the help of Trustees Rowe and Wiseman to attend the meeting with
Cormier, during which he would be confronted, permanently removed from the board
and the church, and the authorities would be notified, if necessary, pending the
financial audit Pastor Weems had already ordered. On December 31, 2021, Pastor
Weems emailed Cormier to inform him that his one-year term as a Trustee had
concluded and that a new Trustee would be appointed to fill his vacated position,
which would lead to this planned meeting.
117. On January 4, 2022, Cormier responded by providing “notice” that he
and two other trustees, Powell and Rowe, were “bringing a full investigation” on
unspecified allegations and “will be asking our board to review the possibility of asking
Stovall Weems to step down as our current Chairman and Senior Pastor role.”
Cormier further claimed that “[b]ased on our bylaws the removal of board members
during this investigation must be put on hold…”
26
118. Pastor Weems responded later that evening, informing Cormier that he
could not initiate such an investigation under Celebration Church’s Bylaws and
advising him of the proper procedures to follow. Pastor Weems also dismissed
Cormier from the Board of Trustees and advised that he would ask the Board of
Trustees to investigate Cormier’s actions over the past year, listing the instances of
fraud for which Cormier would be investigated.
119. On January 7, 2022, now aware of Rowe’s involvement in the plot to
remove him for unspecified reasons, Pastor Weems sent an email dismissing Rowe as
a Trustee based on Cormier’s statements about Rowe’s involvement and an admission
made by Timberlake about which Trustees were involved.
120. On January 7, 2022, almost immediately after dismissing Rowe, Pastor
Weems received a letter (dated January 6) from Rowe and Powell claiming that he
was under discipline, was not in good standing, and was suspended as the church’s
Senior Pastor as a result of “possible improper financial practices and/or failure to
fulfill duties and responsibilities as Senior Pastor.”
121. As these events unfolded, Defendants ensured that they would maintain
ultimate oversight and control over the Weemses’s ouster from Celebration Church
through Middlebrook Goodspeed and the enlistment of ARC attorneys Wedekind and
Ahr to lead the supposed “investigation” of Pastor Weems and K. Weems.
122. On January 8, 2022, Wedekind and Ahr informed Pastor Weems that he
was banned from Celebration Church while he supposedly was “investigated,” barred
27
him from church property under threat of criminal prosecution, and instructed him to
cease all contact with everyone associated with Celebration Church.
123. These acts were wholly improper and violative of multiple Celebration
Church Bylaws.
124. Aware of this, Defendants used Middlebrook Goodspeed and Wedekind
and Ahr to amend the Celebration Church Bylaws to give the Trustees the absolute,
unchecked power they needed to unlawfully oust Pastor Weems from the church.
125. Wedekind and Ahr also proceeded with conducting the sham
“investigation” of Pastor Weems; during which Defendants and Middlebrook
Goodspeed worked closely with Wedekind and Ahr to ensure that the supposed
“investigation” would end in the predetermined outcome Defendants wanted.
126. Well-before the supposed “investigation” commenced, Defendants knew
Cormier and Stewart were involved in embezzling money from Celebration Church
and that the “investigation” could be used to frame Pastor Weems for the
embezzlement and justify ousting him from Celebration Church and thereafter install
leadership Defendants could control (Cormier and Timberlake), avoid paying
Plaintiffs the benefits Celebration Church had already agreed to provide, and use
Pastor Weems as the scapegoat for Cormier and Stewart’s illegal activities while
simultaneously eliminating Honey Lake Farms as competition for Highlands’ Lodge
and stomping-out Pastor Weemses’s anti-church growth message.
127. All the while, Defendants believed that their nefarious plot would never
be exposed because it would be protected by the secrecy of ecclesiastical abstention.
28
128. During the sham “investigation,” the Weemses’s were essentially made
pariahs, unable to defend themselves and isolated from the church, friends, church
members, and professional colleagues and contacts, most of whom they were
prohibited from contacting and had been told the Weemses’s were suspended and
“under investigation” for unspecified reasons.
129. At the same time, Defendants knew the actions they orchestrated had
placed Plaintiffs in significant financial distress.
130. Then, on January 17, 2022, Defendants sent an extortionate email to
Pastor Weems through their agent, Larry Stockstill, an Overseer and Apostolic Elder
of Highlands and Hodges’ personal pastor.
131. In this January 17, 2022 email, Stockstill acting at Defendants’ direction
openly acknowledged Cormier’s embezzlement but insisted that he remain on
Celebration Church’s Board of Trustees:
132. In this January 17, 2022 email, Stockstill acting at Defendants’ direction
also openly challenged Pastor Weemses’s “new direction in ministry” before
summarizing that Pastor Weems was “under investigation financially…banned from
29
the church and it’s property… and no longer [has] a ‘founder’s seat’ and that will
probably not happen,” before laying out in detail the actions Pastor Weems had to
take to “CLEAR [his] NAME,” which included repenting to ARC, Rizzo, and
Seibeling in particular:
133. At the time of this January 17, 2022 email, Pastor Weems and
Celebration Church had no formal relationship with ARC, and ARC had no legal
control over Pastor Weems or Celebration Church. There was no legitimate reason
for ARC or any of the Defendants to be making any demands on Pastor Weems.
30
134. At the time of this January 17, 2022 email, Middlebrook Goodspeed were
also, at Defendants’ direction, refusing to do anything to assist Pastor Weems in
preventing the coup unfolding at Celebration Church and instead insisted that Pastor
Weems “not get an attorney or go to the court.”
135. As time dragged on with no imminent resolution of this incredibly
damaging situation in sight, the Weemses’s decided to take action and filed suit on
February 23, 2022 to try to obtain temporary injunctive relief to protect their rights
and force the resolution of the sham investigation.
136. On March 3, 2022, Wedekind filed a Motion to Dismiss in that lawsuit
which lobbed unsubstantiated, unnecessary personal attacks against the Weemses’s
that were completely irrelevant to the legal arguments it raised and further explained
how Celebration Church’s Bylaws were amended on January 13, 2022, to make its
Board “the highest ecclesiastical authority in the church…”
137. Upon reading this, Pastor Weems came to the difficult realization that he
could no longer be a part of Celebration Church and needed to try to protect his family
from any further attacks by resigning and completely separating from Celebration
Church.
138. Thus, on April 15, 2022, Pastor Weems tendered his resignation as
Senior Pastor, President, Chief Executive Officer, Chairman and member of the Board
of Trustees, and registered agent.
139. However, Defendants were not satisfied with Pastor Weemses’s
resignation, were upset over the lawsuit and the publicity it drew, and were likely
31
fearful that members of Celebration Church’s congregation would follow Pastor
Weems once he began ministering elsewhere and working with other churches.
Accordingly, Defendants continued to work closely behind the scenes with their
attorneys, Wedekind and Ahr, to create and publicly disseminate a false and
defamatory narrative and statements about Pastor Weems and K. Weems, along with
private and confidential information about K. Weems they had unlawfully gathered,
to try to destroy their reputations, humiliate them, and prevent Plaintiffs from
continuing their ministry and missions.
140. This culminated in an April 24, 2022, “Report of Investigation to
Celebration Church of Jacksonville, Inc.”, a copy of which is attached hereto as
Exhibit A (the “Report”), which Defendants ensured was leaked to the press so that it
would be publicly available before ARC’s Conference in South Carolina on April 25-
27, 2022—at which Hodges was planning to discuss the progress of the Highlands
Lodge and plans for GrowLeader.
141. The ultimate purpose of the public dissemination of the Report was to
frame Pastor Weems and K. Weems for embezzling the money Defendants’ knew
Cormier and Stewart had taken and covered up, which could be used to legitimize the
takeover of Celebration Church and ensure the failure of Plaintiffs’ anti-growth vision
and missionary work while simultaneously using Pastor Weems to publicly
demonstrate what would happen to others if they entertained the idea of opposing
Defendants’ modern church growth philosophy.
32
142. Notably, the Report falsely tried to blame Pastor Weems for (among
other things) embezzlement based on a supposed $3 million cash shortfall between
October and December 2020:
143. However, Celebration Church’s own financial statements (prepared by
Stewart) demonstrate that it had a $6 million cash balance in October 2020, not $9
million:
33
144. Cormier and Stewart were in fact the ones responsible for over $3 million
embezzled from Celebration Church, which Timberlake knew about and, at
Defendants’ direction, helped cover up to frame Pastor Weems and help support his
installation as Pastor Weems’s replacement at Celebration Church.
145. Defendants’ knew the Report, which was engineered to make it falsely
appear as if it was the product of a legitimate investigation conducted by a reputable
law firm, could be used to sway the opinions of Celebration Church’s members, the
public, and people and businesses affiliated with Plaintiffs to convince them that Pastor
Weems and K. Weems were criminals—even though the reality was that Defendants
were intimately involved in preparing the Report and its conclusions and the lawyers
who authored the Report it were in fact working for and loyal to Defendants.
146. Although Defendants knew the embezzlement and other criminal
accusations the Report leveled against Pastor Weems were demonstrably false, they
continued to ensure that these accusations were advanced publicly and disseminated
to ensure Defendants’ ultimate objective of destroying Plaintiffs was achieved.
147. Thus, on April 27, 2022, acting at Defendants’ direction, Wedekind
prepared and transmitted a letter via email to TurnCoin, Ltd.’s chief legal officer, Arno
Visser, (the “TurnCoin Letter”), which falsely asserted that Pastor Weems “embezzled
and fraudulently transferred [Celebration Church] funds that were used to purchase
TurnCoin” and engaged in “money laundering…in violation of 18 U.S.C. §§ 1956(a)
and 1957”:
34
35
148. The TurnCoin Letter specifically directed TurnCoin to view the Report
to read about “Weemses’s illegal activities” and included a hyperlink to the Report for
that purpose.
149. This TurnCoin Letter used the Report and false criminal accusations
about Pastor Weems to try to convince TurnCoin to freeze Pastor Weemses’s
investments in hopes of further financially crippling Plaintiffs.
150. Despite knowledge of the actual perpetrators of the embezzlement and
the efforts to conceal it, Defendants ensured that Pastor Weems would be publicly
blamed for it, which not only protected Cormier for his criminal acts but also rewarded
him by ensuring that he would be placed in charge of Celebration Church’s Board of
Trustees.
151. Defendants also further rewarded Timberlake for his role in advancing
Defendants’ conspiracy by partnering with Servolution to promote and generate sales
of Timberlake’s book (The Power of 1440), while simultaneously using the book to
encourage church planting and growth.
152. Based on the agreements and promises made by Celebration Church as
outlined above, the Weemses’s not only stopped drawing a salary from the church but
also invested and gave hundreds of thousands of dollars (almost to the point of
insolvency) to fund the missions Celebration Church had already agreed to fund; all
of which they lost as a result of Defendants’ actions.
36
153. Defendants’ actions also caused losses of committed funding and
agreements to Celebration Global totaling approximately $30 million dollars over a
15-year period.
154. Honey Lake Farms was far down the road to being self-sustaining when
Defendants’ actions caused its committed investors and partners to back out, resulting
in millions of dollars of additional losses.
The Unlawful Means Defendants Used to Tortiously Interfere
155. By engaging in the above-alleged conduct, Defendants conducted,
engaged in, and/or participated in a pattern of unlawful and criminal activity
deliberately intended to harm Plaintiffs and carry out defendants’ conspiracy against
them.
156. Defendants’ conduct alleged in paragraphs 126-134, above, constitutes
racketeering and extortion in violation of 18 U.S.C. § 1961(1)(A) and § 836.05, Fla.
Stat.
157. Defendants’ conduct alleged in paragraph 94, above, constitutes
racketeering and an offense against users of computer systems, networks, and
electronic devices in violation of 18 U.S.C. § 1961(1)(A) and § 815.06, Fla. Stat.,
158. Defendants’ conduct alleged in paragraphs 55-59, 63, 65-68, 92, 94, 113,
121, 126, and 150-151, above, constitutes racketeering and bribery in violation of
18 U.S.C. § 1961(1)(A) and § 838.16, Fla. Stat..
37
the communication of libelous matter to newspapers in violation of violated § 836.09,
Fla. Stat.
racketeering and wire fraud in violation of 18 U.S.C. § 1961(1)(B) and 18 U.S.C.
§1343.
161. Defendants’ overall course of conduct and conspiracy alleged above also
constitutes a scheme to defraud in violation of the Florida Communications Fraud
Act, § 817.034, Fla. Stat.
162. Defendants aided, abetted, counseled, hired, or otherwise procured
others to commit the criminal acts described above and are therefore principals in the
first degree under § 777.011, Florida Statutes.
163. Defendants soliciting others to commit the criminal acts described above,
and in the course of such solicitation commanded, encouraged, hired, or requested
another person to engage in specific conduct which would constitute such offense or
an attempt to commit such an offense, thereby constituting criminal solicitation in
violation of § 777.04(2), Florida Statutes.
164. Defendants agreed, conspired, combined and/or confederated with
another person or persons to commit the criminal acts described above, thereby
committing criminal conspiracy in violation of § 777.04(3), Florida Statutes.
165. Defendants also explicitly or tacitly agreed to participate in a common
scheme and unlawful ongoing conspiracy, in furtherance of which they recommended,
38
agreed to, and participated in committing the criminal acts described above, which
caused significant harm and damages to Plaintiffs as a result.
COUNT I
(TORTIOUS INTERFERENCE)
166. Plaintiffs re-allege and incorporate Paragraphs 1 through 165, as if fully
stated herein.
167. As more specifically alleged in paragraphs 62-64, 70-71, 89-91, and 100-
106, above, Plaintiffs had advantageous contractual and business relationships of
which Defendants were aware.
168. Defendants intentionally and unjustifiably interfered with Plaintiffs’
advantageous contractual and business relationships.
169. As a direct and proximate result of Defendants’ unlawful and tortious
interference with Plaintiffs’ advantageous contractual and business relationships,
Plaintiffs suffered substantial economic damages in amounts to be proven at trial.
170. Defendants’ actions alleged herein were unjustified, unlawful and
committed maliciously and deliberately with an intent to injure Plaintiffs and cause
them substantial harm; were committed with actual knowledge of the wrongfulness of
the conduct and the high probability that injury and damage to Plaintiffs would result,
and despite that knowledge, Defendants intentionally pursued their course of conduct,
resulting in injury and damages to Plaintiffs; and/or were committed in conscious
disregard of the Plaintiffs’ rights.
39
171. As a direct and proximate result of Defendants’ tortious conduct, and in
addition to the quantifiable monetary damages Defendants’ conduct caused, Plaintiffs
also suffered and will continue to suffer irreparable harm for which there is no
adequate remedy at law if Defendants are not enjoined from engaging in such conduct
in the future.
172. Based on the facts alleged herein and to be established at trial, Plaintiffs
have the clear legal right to the entry of an injunction prohibiting Defendants’ tortious
misconduct.
173. The public interest would be served by the entry of an injunction
prohibiting Defendants’ unlawful and tortious misconduct.
WHEREFORE, Plaintiffs demand judgment against Defendants awarding:
a. Compensatory damages in appropriate amounts to be established

at trial;
b. Punitive damages in appropriate amounts to be established at trial;
c. Injunctive relief prohibiting Defendants from engaging in the

tortious and unlawful misconduct alleged herein;
d. Costs associated with this action; and
e. Such other and further relief as the Court deems just and
appropriate to protect Plaintiffs’ rights and interests.
COUNT II
(CONSPIRACY)
174. Plaintiffs re-allege and incorporate Paragraphs 1 through 173, as if fully
stated herein.
40
175. Defendants agreed and conspired with one another to tortiously interfere
with Counter-Plaintiffs’ advantageous contractual and business relationships.
176. In doing so, Defendants agreed and conspired to do an unlawful act or a
lawful act by unlawful means.
177. Defendants each committed overt acts in pursuance and furtherance of
their conspiracy.
178. As a direct and proximate result, Plaintiffs suffered damages in amounts
to be proven at trial.
179. Defendants’ actions alleged herein were unjustified, unlawful and
committed maliciously and deliberately with an intent to injure Plaintiffs and cause
them substantial harm; were committed with actual knowledge of the wrongfulness of
the conduct and the high probability that injury and damage to Plaintiffs would result,
and despite that knowledge, Defendants intentionally pursued their course of conduct,
resulting in injury and damages to Plaintiffs; and/or were committed in conscious
disregard of the Plaintiffs’ rights.
180. As a direct and proximate result of Defendants’ tortious conduct, and in
addition to the quantifiable monetary damages Defendants’ conduct caused, Plaintiffs
also suffered and will continue to suffer irreparable harm for which there is no
adequate remedy at law if Defendants are not enjoined from engaging in such conduct
in the future.
41
181. Based on the facts alleged herein and to be established at trial, Plaintiffs
have the clear legal right to the entry of an injunction prohibiting Defendants’ tortious
misconduct.
182. The public interest would be served by the entry of an injunction
prohibiting Defendants’ unlawful and tortious misconduct.
WHEREFORE, Plaintiffs demand judgment against Defendants, awarding:
a. Compensatory damages in appropriate amounts to be established

at trial;
b. Punitive damages in appropriate amounts to be established at trial;
c. Injunctive relief prohibiting Defendants from engaging in the

tortious and unlawful misconduct alleged herein;
d. Costs associated with this action; and
e. Such other and further relief as the Court deems just and
appropriate to protect Plaintiffs’ rights and interests.
DEMAND FOR JURY TRIAL
Plaintiffs hereby demand a trial by jury on all issues so triable.
Respectfully submitted,
/s/ Shane B. Vogt

Shane B. Vogt – FBN 257620
E-mail: svogt@tcb-law.com
David A. Hayes - FBN 096657
E-mail: dhayes@tcb-law.com
TURKEL CUVA BARRIOS, P.A.
100 North Tampa Street, Suite 1900
Tampa, Florida 33602
Tel: (813) 834-9191
Fax: (813) 443-2193
Attorneys for Plaintiffs
42

Weems Lawsuit Vs Association of Related Churches

Uploaded by

Copyright:

Available Formats

Weems Lawsuit Vs Association of Related Churches

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Weems Lawsuit Vs Association of Related Churches

Uploaded by

Copyright:

Available Formats

Case 3:23-cv-00811-MMH-LLL Document 1 Filed 07/12/23 Page 1 of 42 PageID 1

UNITED STATES DISTRICT COURT

CHARLES S. WEEMS, IV, an individual,

ASSOCIATION OF RELATED CHURCHES,

COMPLAINT & DEMAND FOR JURY TRIAL

Plaintiffs, Charles Stovall Weems, IV (“Pastor Weems”), Kerri Weems (“K.

(“Honey Lake Farms”), NorthStream Management Group, LLC (“NorthStream”),

Seibeling (“Seibeling”), and allege as follows:

OVERVIEW OF THE CASE

1. This case arises out of a continuing unlawful conspiracy masterminded

eliminating them as perceived threats and competitors, which included engineering a

takeover at Celebration Church of Jacksonville, Inc. (“Celebration Church”) to allow

Weemses’s for financial crimes they never committed.

focused on missionary work and developing supporting businesses that Defendants

perceived as a significant threat to their economic interests.

3. Using ARC’s significant influence and power as a vehicle to facilitate and

conceal their nefarious scheme, Defendants intentionally caused substantial financial

computer crimes which ultimately caused over $100 million in damages.

PARTIES, JURISDICTION, AND VENUE

5. This is an action for damages well in excess of $75,000.00, exclusive of

interest, costs, and attorneys’ fees, as well as equitable relief.

6. Plaintiff, Pastor Weems, is a resident and citizen of Duval County,

7. Plaintiff, K. Weems, is a resident and citizen of Duval County, Florida.

8. Plaintiff, Celebration Global, is a Florida not for profit corporation with

10. Plaintiff, NorthStream, is a Florida limited liability company with its

whose sole members are Pastor Weems and K. Weems.

whose sole members are Pastor Weems and K. Weems.

12. Defendant, ARC, is a Texas not-for-profit corporation with its principal

place of business located at 1201 Lee Branch Lane, Birmingham, AL 35242.

13. Defendant, Hodges, is a resident and citizen of Birmingham, Alabama.

14. Defendant, Rizzo, is a resident and citizen of Birmingham, Alabama.

15. Defendant, Seibeling, is a resident and citizen of Memphis, Tennessee.

16. Non-party, Celebration Church, is a Florida not-for-profit corporation

18. Pursuant to 28 U.S.C. §1391, venue is proper in this District because a

occurred in this District.

19. Defendants, directly and/or through employees, agents, authorized

representatives, co-conspirators, subsidiaries, affiliates, and/or other persons, entities,

and/or representatives acting under their management, direction, supervision, and/or

upon which this action is based.

20. Defendants knowingly and intentionally entered into one or more

contracts or agreements, pursuant to which they, directly and/or through employees,

agents, authorized representatives, co-conspirators, subsidiaries, affiliates, and/or

other persons, entities, and/or representatives acting under their management,

acts within and directed at the state of Florida.

an employee, agent, co-conspirator, subsidiary, affiliate, and/or other person or entity

or more of the following acts:

a. committing tortious acts within the state of Florida;

b. committing intentional torts expressly aimed at Florida,

c. operating, conducting, engaging in, or carrying on a

d. engaging in substantial and not isolated activity within the

e. engaging in a conspiracy to commit tortious acts against

22. Based on the facts alleged throughout this Complaint, sufficient

(2) conducted business through employees, agents, co-conspirators, and/or authorized

claims alleged herein in the state of Florida.

employees, partners, joint-venturers, co-conspirators, masters, and/or employers of

partnership, employment, conspiracy, ownership, joint venture, or contractual

omissions, and misconduct in concert or active participation with one another or to

aid or abet one another.