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Court Documents

These documents are included in the court record of the Dallas lawsuit, Brown v. First Baptist Church of Farmers Branch. I hope they may be helpful to other clergy abuse survivors. News of the church’s apology, the lawsuit’s settlement, and the secret file at the Baptist General Convention of Texas, were also reported in Dallas on WFAA-TV (ABC), KTVT-TV (CBS), and KDFW-TV (FOX) on February 20, 2006.

  • Apology letter of First Baptist Church of Farmers Branch, expressing regret for the “very serious sexual abuse” of its prior minister Tommy Gilmore and acknowledging that another church leader was able to substantiate that Gilmore had sexual contact with Brown as a minor. (This apology also shows the still-continuing blindness and ignorance of the church. Even while acknowledging that a church leader knew about Gilmore's sexual contact with a minor, the same letter also tries to excuse it by saying that the church leader didn't realize the seriousness of it. When would it EVER be possible for an adult minister to have sexual contact with a minor without it being something serious???)

  • Settlement agreement.  (1) The Church agrees that its music minister had “knowledge about Gilmore’s sexual contact with Brown as a minor;” (2) The Church does NOT deny the allegations of the lawsuit and nor does it deny wrongdoing but merely disclaims “legal liability;” (3) The Church states that the apology - which is for the “very serious sexual abuse” - is made with “remorse and contrition.”

  • Plaintiff's Amended Petition in the consolidated suit, setting forth more fully the factual allegations, the reasons for tolling limitations, and the allegations on aiding, abetting and conspiring for purposes of joint liability.

  • Trial brief in support of Subpoena for documents in the file of clergy abusers at the Baptist General Convention of Texas. With sworn affidavits on file, this brief also alleges that this single Southern Baptist church, the First Baptist Church of Farmers Branch, has had at least four ministers who were involved in or complicit with sexual abuse, including its current minister Sam Underwood.

  • BGCT email correspondence, included as an exhibit, and showing the BGCT's placement of Gilmore’s name in its confidential file of clergy abusers - a file referred to as the file of "known offenders" - and an excerpt from the BGCT’s "Broken Trust" booklet about the file (entirety of BGCT’s booklet is part of court record)

  • SBC letter of 7/26/2004, saying that the Southern Baptist Convention has no record of Gilmore being a minister in any church (even though Gilmore was at a mega-church in Florida)

  • Letter from First Baptist Church of Farmers Branch, 8/9/2004 (This was not a court-filed document, but it is the document in which the first threat of a lawsuit was made....and that threat was made by the church even though the church's music minister had knowledge of the abuse.)