Steven C. Metzger
3626 N. Hall St., Ste. 800
Dallas, TX 75243
Bruce Thomas
1825 Market Center Blvd., Ste. 200
Dallas, TX 75207
This letter is sent pursuant to Texas Rule of Evidence 408 and is intended for settlement purposes only.
I have been informed that your clients defendants Dr. Girma Wolde Rufael and Abera Pitta were recently defeated for re-election to the St. Michael's board of trustees. I have also been informed that the current board desires to resolve this lawsuit amicably, to move past our clients' dispute, and to return St. Michael's to the peaceful sanctuary it once was.
To that end, my clients and the 150 or so current and former members of St. Michael's who support them spiritually and financially are prepared to forgo any further challenges, provided your clients lay down their swords as well. More specifically, the plaintiffs in this case, and all those who support them, are prepared to forego planned federal litigation provided that your clients dismiss their claims, suspend all of the recent amendments to the bylaws, reinstate all disenfranchised members, and appoint a committee representing all of the interests of the church to review and, if necessary, revise the existing bylaws.
I recognize that this is not in the nature of a traditional settlement proposal and may be difficult to document, but you know_ that this is not a traditional case. I also suspect that, regardless of your clients' formal position in this lawsuit, both you as experience counselors and they recognize that this dispute will continue in one fashion or another in one venue or another until the parties truly achieve peace. Please, therefore, understand and encourage your clients to accept that it is peace my clients desire. As such, we trust that this proposal will be received with the same good faith that it is made.
Counsel
1110/2012
Page2
Finally, I understand that the board of trustees has a meeting this evening. I would ask that you present this proposal to them immediately, so that they will have adequate time to consider it this evening.
