Links to documents, filings and other papers. 

Former Youth Pastor Responds to Open Letter from Church Leaders Who Mishandled and Failed to Report Child Sex Abuse

Titus Benton’s response to the Open Letter from Church Elders 6/25/15 published on

Response to Varvil’s Demand Letter from Wingfield’s Attorney 6-26-15

This is the one page response to Dawn Varvil’s 9 item demand letter asking for counseling for victims, compensation for attorney’s fees, removal of litigation documents from and an apology.

Elders’ Open Letter To the Congregation 6-21-15

This is the letter mailed to congregants, dated 6-21-15, which is basically the written address given in church.  If the copy is no longer available on the web site, get it here.

Resignation Request Letter to Elders 6-15-15.

This is the letter requesting the resignation of Steve Wingfield, Senior Pastor of First Christian Church of Florissant, emailed to the congregation, 6-15-15 from Restore-FCCF.

Varvil’s Negotiation Letter to Steve Wingfield and FCCF 6-4-15

This letter lists 9 things FCCF should do concerning abuse problems within the church.

Professor Doug Lay’s Letter of Resignation to SLCC

Professor Lay’s 5/18/2015 resignation letter and link to pdf version.

Can a Church Ever File a Lawsuit (from

This is the explanation given as a pdf file on, 4/25/15, concerning whether it is permissible for a church to sue its members.

Letter from Doug Lay’s lawyer to Steve Wingfield and FCCF

This is a 4-page letter dated 4/27/15, from A.W. Johnson (Doug Lay’s lawyer) to James R. Wyrsch, lawyer for Steve Wingfield and FCCF.  The letter makes counter points to the issues raised in the Questions and Answers document posted on the web site.

In this letter, Johnson demonstrates how Wingfield and Wyrsch have not responded to 3 documented requests for a meeting between Doug Lay and Steve Wingfield.  Johnson also says that the information presented in the Q&A document is incorrect and goes point-by-point through the assertions listed in the Q&A and explains why they are wrong.

Doug Lay’s Motion to Dismiss

In this 14-page, 4-27-15 motion, lawyer A.W. Johnson gives the Court a number of reasons why the this case should be dismissed.

Open Letter from Senior Pastor and Elders, 4-25-15

This is an open letter that generally follows the announcements that were made from the pulpit.  If it is no longer available at, get it here.

Questions and Answers -4-24-15

What has the church been accused of and why address it in a public manner?
Why have we invited the civil courts into this matter?
What about the current safety of our children and teen students?
How will we move forward as a church family and what do your elders ask of you?

This was the elders’ Q & A sheet answering the above questions.  If the copy on has been removed, get it here.

The Lawsuit Filed in St. Louis County

This is the “Verified Petition” filed in the St. Louis County Courts, 4/16/15, by Steve Wingfield and First Christian Church of Florissant.  It is a 54 page document, however only the first 12 pages are visible on (the church’s website.)  The remaining pages contain exhibits which include the “case study” by Doug Lay, and a letter from Dawn Varvil.

The petition:

Count 1 – Ask for injunctive relief (an injunction to prevent the defendants Dawn Varvil, Doug Lay, Titus Benton and Kari Benton, all members or former members of FCCF, from talking about the 2012 incident with Brandon Milburn and First Christian Church)

Count 2 – Specifies a claim for Defamation against all defendants.

Count 3 – Specifies a claim for “Injurious Falsehood” against all defendants.

Count 4 – Specifies a claim for SLANDER against Dawn Varvil.

Count 5 – Specifies a claim for Negligent Infliction of Emotional Distress against all defendants.

WHEREFORE, Plaintiff demands judgment against Defendant as follows:

(a)  For compensatory damages in excess of $25,000;

(b)  For punitive damages;

(c)  For their cost of suit, including reasonable attorneys’ fees incurred herein;

(d)  For an order

a.  Barring Defendants from making or publishing false statements regarding the September 2012 conversation, including the false claims that Plaintiffs were told of sexual abuse allegations and failed to report them to authorities;

b.  Requiring Defendants to delete any posts, comments, articles or other
publications of the false statements; and

c.  Requiring Defendants to formally retract the statements regarding the
September 2012 conversation and admit that they are false; and

(e)  For such other and further relief as this Court deems just and proper.

Motion for Temporary Restraining Order

Steve Wingfield and First Christian Church of Florissant file a request for a Temporary Restraining Order against Dawn Varvil, Doug Lay, Titus Benton, Kari Benton and a Jane Doe 4/16/15 in St. Louis County Court.  The restraining order request was refused by the Courts.

Memorandum In Support of Temporary Restraining Order

Online petition to remove FCCF as a named defendant from the lawsuit

Jim Taylor Statement to the congregation 4-12-15

This was the prepared statement read by Jim Taylor to the congregation 4/12/15 from the pulpit.

Q & A Meeting 4-8-15 – Steve Wingfield & Elders

This is a transcription of the meeting 4-8-15 held at First Christian by Steve Wingfield and the elders to answer questions about the Brandon Milburn case as a “family meeting”.

Serious Answers for Serious Problems  4-7-15

Letter from Doug Lay — For several weeks, Facebook has lit up with comments about “something going on” at First Christian Church of Florissant. People want quick and simple answers—which Facebook can easily supply. But questions about serious issues confronting the church require serious answers—they require time to read, to study, to pray, to consider before jumping to conclusions without a solid foundation of the facts.  Although people are talking about an array of issues online, this letter focuses on one main serious problem at hand at FCCF:

FCCF Meeting Summary 4-1-15

Location: FCCF Student Ministry
Invitees: Children’s Ministry Workers (invited by Pam Giese via email to those in church database)
Facilitators: Steve Wingfield, Jim Taylor, and Bob Farmer
Topics: Brandon Milburn, recent social media posts, Steve’s pastorship, and a Q&A

Is it Enough – First Christian Church of Florissant Case Study

Case study, 3/28/15, by Professor Doug Lay and former FCCF youth pastor Titus Benton that outlines the systematic cover up of reported child sexual abuse.  This is the document that is the target of the defamation law suit filed by the senior pastor and First Christian Church of Florissant against five of its former members.