Gary W. Loveless
5847 San Felipe, Suite 2900
Houston, Texas 77057
713-266-3741
gloveless@sqmenergy.c0m

June 29, 2018

Mr. Kevin M. Ueckert and Members of the
Executive Committee of the Board of Trustees
Southwestern Baptist Theological Seminary
Fort Worth, Texas

Dear Mr. Ueckert and Executive Committee Members:

Please allow this letter to express our utter disdain for your actions on May 30,
2018, regarding Dr. Paige Patterson.

The illegal manner by which that meeting was called and conducted, your
statement on May 30, 2018 which was completely devoid of any speci?c charge against
Dr. Patterson, followed two days later by Kevin Ueckert?s statement defaming Dr.
Patterson, all point to an abuse of power which is anathema to the moral and ethical
principles embraced by an honorable people.

The full meeting of the Board of Trustees held on May 22, 2018 determined the
professional fate of Dr. Patterson and his relationship with Southwestern Seminary.
Proper notice was afforded to Dr. Patterson, as he initiated that meeting himself,
nonetheless the protocol followed that day was anything but proper. Your failure to
afford even a modicum of due process to Dr. Patterson was a complete miscarriage of
justice. During that long 13-hour plus session, Dr. Patterson and his staff were allowed
very limited access to the information provided the Trustees, along with even more
limited opportunities to be present and participate in discussions with the Board. Further,
neither Dr. Patterson nor his attorney knew in advance the possibility that such extreme
action against him would take place. In fact, prior to that meeting the information
disseminated from members of the Trustee Board itself, was that any vote to remove Dr.
Patterson was neither anticipated, nor would it be appropriate.

With the one exception of not agreeing to meet with the Executive Committee
prior to the May 22?1d full Trustee Board meeting, Dr. Patterson has never in all his time
at the Seminary ever refused to meet with either the Executive Committee or Board
upon receiving such a request. On those few occasions when he was away from the

Mr. Kevin Ueckert
June 29, 2018
Page 2

Seminary, he always assured that a member of his cabinet was in attendance. The
allegations made by Bart Barber on the ?oor at the SBC Convention were contrary to
those facts and thus, in our opinion, were false and slanderous. Further, the fact that the
presiding president, Steve Gaines, allowed such unacceptable statements to continue as
he did without Mr. Barber being ruled out of order was, to our knowledge, the ?rst time
that a presiding of?cer of the SBC Convention has so ?agrantly ignored the rules of the
Convention to allow fallacious personal attacks by one member against another.

If all your actions toward Dr. Patterson had been limited to the events of May 22,
2018, your actions would have been completely unwarranted and unacceptable; however,
you proceeded further. Your actions toward Dr. Patterson on May the 30th are as
indefensible in their substance as they are legally illegitimate in the manner in which they
took place. You were well aware at that time that Dr. and Mrs. Patterson were in
Germany, and that he was preaching at an engagement that had been scheduled months
earlier. This fact, apparently for your purposes, presented you with a convenient
opportunity to hastily assemble (in complete violation of your By-laws) and take the most
severe actions imaginable against Dr. Patterson, without affording him or his counsel any
notice whatsoever. Interestingly, even if Dr. Patterson had independently learned of your
May 30th meeting, it would have been impossible (as you well knew) for him to have
made an emergency return to the Seminary. We submit that you conceived and executed
your plan to remove Dr. Patterson in the darkest of secrecy.

In legal terms, you conducted an ex parte hearing. Such ?one party only?
hearings are allowed in our civil courtrooms only when there exists such imminent harm
to the petitioner and time is of such an essence, that immediate action must be taken to
avoid perilous and irreputable harm. Such was not the case on May the 30th. Rather, the
only assumption to be drawn is that you assembled and took the action you did regarding
Dr. Patterson because you believed that you could. You are not bound by the same
professional ethics that govern attorneys and our Court proceedings. In truth, you are
actually bound by higher Biblical standards of honesty and fairness as set forth in
Leviticus 19:35-3 7, which sadly, as your actions attest, you chose to abandon that day.

You are well aware of the legal problems associated with your failure to give
timely Notice for the May 30th meeting, as required by your By-laws. You are also
aware that you failed to give proper Notice regarding the drastic action you intended to
address and thereafter take. We highlight those failures to acknowledge their on-going
legal signi?cance. We anticipate that as a result of your actions that day, the Seminary
will face significant consequences both from its accrediting board, the Southern
Association of Colleges and Schools, and the Texas Attorney General?s of?ce.

The May 30, 2018 Statement by the Executive Committee Board refers only to
?new information? and ?details presented? in a vague attempt to explain your

Mr. Kevin Ueckert
June 29, 2018
Page 3

indefensible actions against Dr. Patterson. We note the careful selection of your words,
you state that this new information involved a situation that occurred ?during Dr.
Patterson?s presidency at another institution,? (emphasis added) but you intentionally
(and we might add, correctly) did not state that the situation involved Dr. Patterson
himself. We submit you chose your words as you did because while you knew Dr.
Patterson had not done anything wrong, you nonetheless wanted to create the impression
that he had. Your statement, while it clearly demonstrates a callus level of injustice and
dishonesty towards Dr. Patterson himself, of equally great harm is the damage it does to
the integrity of Southwestern Seminary itself.

Two days later, Mr. Kevin Ueckert issued a personal statement on June 1, 2018,
attempting, as he stated, to address a number of questions he received regarding the
Executive Committee?s actions. First, (as noted above) he referred to an incident that
allegedly took place when Dr. Patterson was President of Southeastern Seminary.
However, rather than reveal and explain in any detail what such ?information? involved
that appeared to have been pivotal to the Executive Committee?s actions, Mr. Ueckert
states, ?this information contradicts a statement previously provided by Dr. Patterson.?
To this very day, no one outside of the few members of the Executive Committee knows
anything whatsoever about the information to which Mr. Ueckert was referring, although
requests for that information have been repeatedly made by Dr. Patterson and his counsel
and have been repeatedly denied by you.

All anyone knows is that Mr. Ueckert acknowledges the receipt of ?information?
which he then unilaterally declares to have contradicted an earlier statement by Dr.
Patterson. Mr. Ueckert?s statement implies the obvious, that Dr. Patterson had earlier lied
to the Board of Trustees at its May 22nd meeting. Mr. Ueckert?s failure to provide any
details, facts, or any documentation to support his claim of a ?contradictory? statement
having been made by Dr. Patterson obviates his assertion.

We are not aware that you made any request of Dr. Patterson for any information
or documents regarding the alleged 2003 Southeastern event to which Mr. Ueckert refers
in his June 1 statement, prior to the May 22nd meeting or prior to the May 30th meeting.
Dr. Patterson, when told about the alleged event at Southeastern during the May 22
meeting, honestly stated on that day that he had no recollection of the event as you
described it to him. You have no proof whatsoever that he was not speaking honestly
when he stated on May the 22nd that he had no such recollection.

It appears from Mr. Ueckert?s June 1 statement that discussion of this alleged
Southeastern 2003 event resurfaced during the May 30th meeting. We reiterate our earlier
point, at no time prior to the May 30th meeting did you ask for any information or
documentation whatsoever from Dr. Patterson or from Southwestern Seminary regarding
that alleged 2003 event: however, it is readily apparent from Mr. Ueckert?s statement that

Mr. Kevin Ueckert
June 29, 2018
Page 4

there were private and secretive discussions with individuals from Southeastern
Seminary.

Further, to Mr. Ueckert?s assertion in his June 1 statement that Dr. Patterson
improperly took documents ?upon his departure from Southeastern,? we are well aware
that you are equally aware of the true facts surrounding the acquisition and dissemination
of the four documents referred to in his statement. These ?documents? were among the
hundreds of personal letters that Dr. Patterson brought with him from his years at
Southeastern as part of his personal keepsakes. On Tuesday, May 29, 2018, individuals
at Southwestern, upon looking into Dr. Patterson?s personal keepsakes, located
correspondence between Dr. Patterson and Megan Lively (then Nicholas). First, there is
a personal letter dated, April 15, 2003 written ?om Megan Nicholas to Dr. Patterson
acknowledging that whatever event that did Occur in 2003, all matters associated with it
were handled by Dr. Mosely and not by Dr. Patterson. Dr. Patterson?s reply of April 21,
2003, was kind and af?rming of his con?dence in her and the Lord. A second written
exchange occurred three months later, when Megan again wrote to Dr. Patterson on July
23, 2003, sharing her thoughts about ?how blessed the Southwestern faculty and
students? were going to be to have him as their President. Dr. Patterson replied on July
30, 2003, thanking her for her ?precious words of encouragement? and assuring her of his
continued prayers.

Those four personal letters, based upon a clear reading of them on their face,
con?rm Dr. Patterson?s statements to the full Trustee Board that he did not recall
anything associated with this event because he did not personally meet with this student
nor did he have any involvement in the alleged events that took place in her life at that
time. More importantly, their exchange revels a very af?rming and favorable relationship
that they had with one another. If you had you asked for any information or written
documentation between these parties, prior to your May 30th meeting, the personal
correspondence between Dr. Patterson and Ms. Nichols would have been provided.

Sadly, rather than accept responsibility for the Executive Committee?s own
shortcomings, Mr. Ueckert wrongly asserts that the release of those letters by Sharayah
Colter, the wife of Dr. Patterson?s chief of staff, was inappropriate and unethical. In
truth, it was her courageous act in publishing those letters, along with her narrative, that
can best be described as ?having struck the match that lit the ?rst candle? of shedding
light on the darkness of your unconscionable actions.

It is doubtful that the true facts of what did or did not occur in 2003 at
Southeastern Seminary will ever be known. Countless facts are now available, of which
you are aware, presenting primafacie evidence of contradictory statements made
by the alleged victim. All told, there is no justi?cation for the Southwestern Executive
Committee?s failure to undertake an exhaustive investigation, including but not limited to

Mr. Kevin Ueckert
June 29, 2018
Page 5

extensive discussions with Dr. Patterson, in an effort to determine the truth of the events
that allegedly occurred more than 15 years ago at another institution, before acting as
irresponsibly as it did on May 30, 2018.

In contrast, the facts regarding the 2015 Southwestern event referenced by Mr.
Ueckert in his June 1 statement are well known. It is our understanding that you knew
full well that the female student?s allegations of rape were false, that she had engaged in
consensual sexual activities on more than one occasion and those acts had taken place in
public buildings at the Seminary, and that campus security were shown the nude pictures
she texted to the male student. It is our further understanding that you knew full well that
she begged Dr. Patterson to not call the police, but he insisted that he would and he did so
within six minutes of hearing her allegation.

At the meeting of the Board of Trustees held on May 22, 2018, the email
subsequently referenced by Mr. Ueckertin his June 1 statement was presented to the
Trustee Board and discussed thoroughly. This email was written by Dr. Patterson to the
Chief of the Campus Security a full ?ve weeks after he ?rst met with the female student
and reported her allegation to the police. The full Board understood and accepted Dr.
Patterson?s explanation of the phrase ?breaking her down? that appeared in that email as
being a statement of his desire to meet with her (without the police present, but clearly, as
was always his practice, with other Seminary personnel present) and attempt to help her
recant her false allegations of rape before she continued with such false statements to the
police. While the actual sentence for a criminal conviction of making a false statement to
the police may vary from jurisdiction to jurisdiction, the criminal offense itself remains a
permanent mark on an individual?s record.

The statement issued by the Board of Trustees on May 23rd is evidence that the
Trustee Board accepted Dr. Patterson?s explanation and appropriately exonerated him
fully of all matters associated with the 2015 Southwestern event.

It is obvious from Mr. Ueckert?s June 1 statement that discussion of that email
and the 2015 Southwestern event resurfaced at your May 30th meeting, although no direct
reference was made to it in your statement of that day. Mr. Ueckert?s decision to release
neither the full email nor the complete explanation provided by Dr. Patterson, but rather
to release only the three-word phase, ?breaking her down,? can only be viewed as one of
the most per?dious, dishonorable, and manipulative ploys ever conceived to disseminate
false and deceptive information.

The only assumption that can be drawn is that Mr. Ueckert, in his June 1
statement, acted in a premeditated manner and with malice aforethought to intentionally
mislead others, while simultaneously defaming and disparaging the honorable name of
Dr. Patterson. It surely stretches the imagination to think that Mr. Ueckert would not

Mr. Kevin Ueckert
June 29, 201 8
Page 6

have known in advance that by selectively using the phrase of ?breaking her down?
(without the complete explanation that earlier had been accepted by the full Board), that
his phrase would be immediately and enthusiastically embraced by the media to further
expand their false narrative and image of Dr. Patterson as gravely as possible.

Mr. Ueckert, with the release of that three-word portion of the email in the
deceitful manner in which he did, thereby attempted to create out of whole cloth the
foundation for his next statement, which we contend is the most abhorrent of all: ?The
attitude expressed by Dr. Patterson in that email is antithetical to the core values of our
faith and to Mr. Ueckert?s actions were alarming. The statement is patently
false, and we submit that Mr. Ueckert knew it was false at the time he made it.

We submit that Mr. Ueckert should bear personal responsibility for the irreputable
harm his statements created. We further submit that all the members of the Executive
Committee, as trustees of the Seminary, bear equal responsibility for allowing his
statements to go uncorrected and by failing to so act, they gave their blessings to his
statements. The legal de?nition of a trustee is that of one who acts in a fiduciary capacity
on behalf of the individual or institution they serve. This is not an ecclesiastical term
with ecclesiastical responsibilities. This is a legal term with legal responsibilities. Your
legal ?duciary obligations to speak truthfully and act honorably, in all your actions and in
all matters involving your association with the Seminary, we submit, were grievously and
irresponsibly ignored from May 23 forward.

Dr. and Mrs. Patterson continue to have our absolute and unwavering support.
They are both esteemed scholars and were stately ambassadors for the Seminary. Your
treatment of them is a travesty that must not go unaddressed. You have clearly failed to
produce any convincing documentation for so drastic an action, against so signi?cant an
individual, in so sudden and short a period of time. Moreover, we submit, there is now
evidence that acts of a dishonest and disreputable nature occurred.

We acknowledge that we have been greatly blessed ?nancially by our wonder?ll
God, in ways far beyond anything we could begin to deserve. It has been because of Dr.
Patterson?s unwavering commitment to proclaiming the entire truth of God?s Holy Word
in his preaching, teaching and the building up of Southwestern Seminary, that we have
enthusiastically given large ?nancial gifts to the Seminary. We have always had
complete con?dence that under Dr. Patterson?s wise stewardship, our ?nancial gifts were
Kingdom gifts to the Glory of our Lord and Savior, Jesus Christ. We believe our
investment in the Seminary has been substantial in the commitment of our time, talents,
prayers, and ?nancial support. Our past ?nancial gifts to the Seminary total in the
millions of dollars. Our ?lture possible gifts, and bequests from our estates, we estimate
could be well in excess of tens of millions of dollars.

Mr. Kevin Ueckert
June 29, 2018
Page 7

Please know that until the serious wrongs against Dr. and Mrs. Patterson are
righted, we will be unable to continue our ?nancial support of the Seminary.

We ask that the full Board of Trustees meet forthwith, and in accordance with its
?duciary responsibilities, appoint an investigative committee to review thoroughly all
recent actions involving Dr. Patterson. The By-laws allow a majority of the members of
the full Trustee Board to call such a meeting and thus the convening of the full Board
does not rest solely in the hands of its chairman. We ask that the composition of this
investigative committee consist of ten individuals - ?ve members selected by the full
Board of Trustees, ?om either the Trustee Board or from individuals of?cially associated
with the Seminary, and ?ve individuals to be selected by the signatories of this letter. The
chairman of the Board of Trustees shall not serve as an ex o?icio member.

If the results of this investigation fail to substantiate the allegations made and the
actions taken against Dr. Patterson, or if the investigation reveals evidence of dishonest
or deceptive activity by anyone associated with the recent actions taken against Dr.
Patterson, then it will be incumbent upon the full Board of Trustees to instruct Mr.
Ueckert and the Executive Committee to revoke its earlier statements, publicly apologize
to Dr. Patterson, and for the full Board of Trustees to restore Dr. Patterson to the ?nancial
position he held at the conclusion of the May 22nd meeting. Should the Board of Trustees
elect to take the restorative action as noted herein, without creating the investigative
committee we request, we would be pleased with that action.

We, as our names are listed below, are all co-signatories to this letter and we
appreciate your immediate attention to the issues we raise.

1"


1/

oveless?
i K?r" 

 

Susan G. Oliver Stephanie Loveless

Dale Linda Behan Mandi Eudora Fleming
John St. John Curtis Oneta Tally

Humphrey Jim Dorothy Merritt
Mollie Allen Fred Pam Gough

Jim Elaine Hastings Danielle Dearing

Richard Gina Hendrick Brown Barbara Adkins
Leonard Lynette Hruzek Mike Zan Prince

CC: Southwestern Baptist Theological Seminary Board of Trustees