Mr. Galen Green
3560 Broadway #323
Kansas City, MO 64111
February 6, 2001
Dean of Students
Saint Paul School of Theology
5123 E. Truman Road
Kansas City, MO 64127
Dear Sir or Madame:
I was an M. Div. candidate at St. Paul from August of 1983 until May of 1984. As a result, I am currently the respondent in a federal civil action, entitled United States of America v. Galen L. Green (Civil No. 00-0385-CV-W-2). Before I continue, please allow me to assure you that neither you nor the seminary nor the United Methodist Church nor anyone affiliated therewith are now or are going to be party to or in any way whatsoever implicated in this suit. Furthermore, please understand that all statues of limitations, both criminal and civil, have long since expired on any and all interactions between myself and any of the aforementioned entities. In short, your/
their culpability is not at issue here.
However, as a result of extreme socioeconomic hardship over the past 17 years, I am compelled to represent myself pro se in the civil matter at hand. Therefore, I trust that you will accept this letter from me in lieu of a subpoena of the documents I will be requesting herein. If either you or your colleagues have questions regarding this or any other parts of this letter, I invite you to address them to:
David DeTar Newbert
(Missouri Bar No. 33588)
Assistant United States Attorney
Charles Evans Whittaker Courthouse
400 E. 9th Street, Room 5510
Kansas City, MO 64106
As attorney for the plaintiff in this case, Mr. DeTar Newbert will, I’m sure, be more than happy to answer any questions, in particular, any that may be raised with regard to the legitimacy of my subpoena power in this matter.
The assistance I am writing here to request from you as a representative of the entire faculty and administration (both past and present) of Saint Paul School of Theology is as follows:
Please accept this letter as my formal request for facsimile copies of any and all documents which in any way whatsoever pertain to me or to my relationship and/or interaction with your institution, either before, during or after my tenure there from 8/83 - 5/84. To pre-empt the accidental, incidental, inadvertent, and/or intentional destruction, alteration and/or mislaying of such documents (be they paper originals, microfilm or fische, digitally stored, or whatever), please allow me to specify that this request includes (but is by no means limited to) any and all such documents in existence on the 19th day of January, 2001, anywhere at all in the physical universe.
This request especially includes (but is by no means limited to) any and all confidential and/or private documents, internal memoranda, informal (personal) notes, journal entries, personal correspondence, etc. as well as any and all other discoverable materials of this nature which may be in the possession of parties at any time affiliated with your institution, if perhaps not to be found currently in the seminary’s actual files.
In January of 1990, a warehouse fire in downtown Wichita, KS destroyed my personal copies of all relevant documents pertaining to my interactions with Saint Paul School of Theology. Of these, the documents most critical to building my case in the federal matter in question would have been the several letters I wrote to members and/or committees of the faculty and administration at the seminary, proclaiming my innocence of any wrongdoing and requesting details of whatever accusations of wrongdoing were providing the impetus for the seminary’s witch-hunt which eventually destroyed my hopes for a career in the United Methodist ministry and consequently brought me to economic ruin and social ignominy.
Please know that I very much appreciate your kind assistance in expediting this matter. And I understand that you will probably need to run this past the seminary’s legal advisers before responding. However, please understand also that the documents of which I am herewith requesting copies are of critical importance in building my case in the suit in question and that I am compelled to perform discovery within the federal court guidelines, time constraints and time frames. I am, therefore, requesting that all discoverable documents mentioned herein be forwarded to be (or made available for me to pick up) no later than March 15, 2001. I will, of course, be happy to pay any reasonable copying and shipping costs. Simply bill me at the above address.
Something else I would be very grateful if you could possibly help me with (besides the items associated with my personal interactions with St. Paul) is whatever general printed information might be available from the academic year 1983-84. This would certainly include (but by no means be limited to) the seminary’s 1983 catalogue and student body directory, as well as policies and procedures regarding discipline and due process afforded students accused of wrongdoing. Again, simply bill me for all such discoverable documents at the above address.
Finally, I would find it very helpful if you would be so kind as to acknowledge receipt of this letter, at your earliest convenience. I can always be reached at the above address. And the 435-7775 voicemail/pager number is picked up day or night 24/7/365.
And, again, Mr. DeTar Newbert and/or his staff at the U.S. Attorney’s office downtown will, I’m sure, be delighted to provide clarification in this matter, should the need arise.
Thank you very much for your patience and attention. I Iook forward to hearing from you at your earliest convenience.