Faith Center Church Evengelist Ministries et al v. Glover et al

Filing 102

STIPULATION on Briefing Schedule for Cross-Motions for Summary Judgment by Faith Center Church Evengelist Ministries, Hattie Hopkins. (Attachments: # 1 Proposed Order)(Chandler, Timothy) (Filed on 9/8/2008)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ALLIANCE DEFENSE FUND BENJAMIN W. BULL Arizona State Bar No. 009940 GARY S. McCALEB (admitted pro hac vice) Arizona State Bar No. 018848 15100 North 90th Street Scottsdale, AZ 85260 Phone: (480) 444-0020; Fax: (480) 444-0028 ALLIANCE DEFENSE FUND TIMOTHY D. CHANDLER California State Bar No. 234325 101 Parkshore Dr., Suite 100 Folsom, CA 95630 Phone: (916) 932-2850; Fax: (916) 932-2851 LAW OFFICES OF TERRY L. THOMPSON TERRY L. THOMPSON California State Bar No. 199870 P.O. Box 1346 Alamo, CA 94507 Phone: (925) 855-1507; Fax: (925) 820-6034 (designated local counsel) Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA FAITH CENTER CHURCH EVANGELISTIC MINISTRIES, et al., Plaintiffs, v. FEDERAL D. GLOVER, et al., Defendants. CASE NO. C-04-3111 JSW DECLARATION OF DR. HATTIE M. HOPKINS IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT FAITH CENTER V. GLOVER HOPKINS DECL. IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-04-3111 JSW 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Dr. Hattie M. Hopkins, declare as follows: 1. I am the leader of Faith Center Evangelistic Ministries ("Faith Center") and a plaintiff in the above-captioned matter. If called as a witness, I could and would testify competently to the truth of the matters set forth in this declaration. I make this declaration based on my personal knowledge. 2. As a Christian, I am instructed by the Bible to communicate my religious beliefs with others, and to help equip others to overcome the many challenges that they face in their lives. 3. I believe that there are many individuals who would benefit from learning about Christianity and the Bible, but who may be unwilling to set foot inside a church building. So I hold Faith Center's meetings in buildings other than traditional church buildings. 4. These meetings typically include what I call a time of "praise and worship." As I use the phrase, "praise and worship" includes discussions about the Bible, teaching, sermons, singing, praying, sharing testimonies, taking communion, and other similar activities. The time of praise and worship is an opportunity for people to gather together to acknowledge the existence of God and to collectively express their love for Him. All "praise and worship" involves teaching about who God is and helping us to develop our moral character so that it is consistent with what the Bible teaches. Specifically, I try to emphasize Biblical directives about moral character, like loving God and our neighbors, helping the weak and poor among us, and leading productive lives as responsible citizens. 5. To this end, I generally preach a sermon as part of Faith Center's "praise and worship" time. My sermons take principles from the Bible and communicate them in a way that anyone can apply them to their life. My sermons cover topics like: developing strong character; developing good self-esteem by understanding how God sees us; overcoming addictions and harmful habits; learning to forgive; knowing how to have a good relationship with God and others; having patience; learning to rely on God to provide for all of our needs; learning how to deal with rejection; and overcoming fear, anxiety, and depression. I always try to have the songs, prayers, testimonies, and other activities making up the time of praise and worship compliment FAITH CENTER V. GLOVER HOPKINS DECL. IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-04-3111 JSW 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and build upon the lessons in my sermon. 6. This time of "praise and worship" is not the only time that I, or Faith Center as a group, engage in worship. I understand worship to be an outward expression of a relationship with God. I believe that God is intimately involved in every aspect of my life. And any time I am doing something that is in accordance with what God would like me to do, that is an act of worship. So I try to be continually in worship. 7. As a result, it is impossible for meet to distinguish between worship and any other aspect of Faith Center's meetings. I use the phrase "praise and worship" based on my own personal and theological understanding of those terms, and other people may define those terms much differently. 8. On May 29, 2004, Faith Center sponsored a "Women of Excellence Conference," which was held in the Antioch Library meeting room. The Conference was divided into four parts: (1) registration from 10:30 a.m. to 11:00 a.m.; (2) a "Wordshop" from 11:00 a.m. to 12:00 p.m.; (3) refreshments from 12:00 p.m. to 1:00 p.m.; and (4) a time of "Praise and Worship" with a sermon from 1:00 p.m. to 3:00 p.m. 9. The topic of the Wordshop was "The Making of an Intercessor." Using lessons from the Bible, the Wordshop explained the need for all Christians to pray, and it gave instruction on how to pray fervent, effectual prayers that God hears and answers. 10. The "praise and worship" session consisted of several elements. We opened with a group prayer. This prayer served several purposes. It helped the group to come back together following the time of refreshments and prepare them mentally and spiritually to learn more from the Bible. It also provided a model to those attending the conference what the Wordshop taught about effectively communicating with God. Finally, it provided the conference, as a group, the chance to acknowledge personal and community struggles that were affecting those in attendance and ask for God to show us how to remove those struggles and heal the community. Praying in this way helps to communicate to others that they are not alone in trying to overcome whatever problems they are faced with. 11. Following the opening prayer, we sang a song together as a group entitled "When FAITH CENTER V. GLOVER HOPKINS DECL. IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-04-3111 JSW 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I See Jesus." The lyrics of the song are as follows: When I see Jesus, I'll say "Amen" When I see Jesus, say "Amen" When I see Jesus, "Amen" Hallelujah, Anyhow I won't let my troubles get me down I don't care what comes my way Hold my head up high and say Hallelujah, Anyhow. 12. I chose this song to help communicate to the conference attendees that, in Jesus, they can find the strength to face difficult situations that may otherwise be impossible to get through. This is directly related to the earlier teachings about prayer because prayer is the way that we can directly connect with Jesus. This song helps show that developing a strong relationship with Jesus through prayer provides hope, encouragement, and strength, even when we are going through difficult times personally or in our community. 13. After we sang "When I See Jesus," I invited a friend, Carol Stone, to sing a solo of the song "Amazing Grace." The lyrics of "Amazing Grace" are, in part, as follows: Amazing grace, how sweet the sound That saved a wretch like me! I once was lost, but now am found, Was blind, but now I see. `Twas grace that taught my heart to fear, And grace my fears relieved; How precious did that grace appear, The hour I first believed. FAITH CENTER V. GLOVER HOPKINS DECL. IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-04-3111 JSW 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14. Through many dangers, toils and snares, I have already come; `Tis grace has brought be safe thus far, And grace will lead me home. Like the previous song, I chose "Amazing Grace" to reinforce what was taught at the Wordshop. It is very common for people to feel uncomfortable with prayer because they believe that they have made too many mistakes in their lives that God will not listen to them. But this song teaches that God accepts us and loves us unconditionally, and that He will help us to overcome whatever problems we are facing. This song helps affirm that everyone, regardless of their past, can effectively communicate with God. 15. Following "Amazing Grace," I gave a sermon entitled "Position Yourself for Victory." My sermon was based on 2 Chronicles 20, which tells the story of Jehoshaphat, the King of Judah, who prayed to God for protection when Judah was being invaded by groups from other lands. God answered his prayer and protected Judah from invasion. 16. My sermon was designed to reinforce what was taught during the morning Wordshop. Jehoshaphat's story shows the power of prayer. My sermon explained that if we want to positions ourselves for victory and overcome the problems in our lives and in our communities, we have to be able to effectively communicate with God. This requires us to first know who God is and have a relationship with Him. Then we must develop the moral character to avoid being self-centered, to love others as ourselves, and to be willing to seek God on their behalf. Then we can learn to effectively communicate with God through prayer. And only then can we overcome the personal and societal problems we are all affected by. 17. The afternoon session concluded with a closing group prayer. Much like the opening prayer, it provided a model to those attending the conference of what the Wordshop taught about effectively communicating with God. It also encouraged the attendees to continue applying the principles that they had learned after the conference was over. And we again prayed for personal and community problems that were affecting the group. FAITH CENTER V. GLOVER HOPKINS DECL. IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-04-3111 JSW 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18. At the end of this conference, I was informed by two Antioch Library employees, Jenna Biglow and Lisa Loomis, that groups were not permitted to use the meeting room for religious purposes. 19. I asked if the reason for the prohibition was because of excessive noise from the Faith Center meeting. The Library employees said that there was no noise problem with Faith Center--the only problem was that Faith Center was conducting a religious meeting. 20. After the District Court granted my motion for a preliminary injunction, Faith Center held several additional meetings at the Antioch Library meeting room. 21. I have never been told by a Library employee that any of those meetings created any excessive noise or that people could hear us outside of the meeting room. 22. I also discovered that more people were able to attend Faith Center's meetings at the Library if I scheduled them for Saturday evenings starting at 6:00 P.M., which is after the Library has already closed. 23. I would like to reserve the Antioch Library meeting room for future Faith Center meetings, and I expect to continue to have them on Saturday evenings after the Library has closed. // // // // // // // // // // // // FAITH CENTER V. GLOVER HOPKINS DECL. IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-04-3111 JSW 6

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