Bill Gothard and IBLP File Motions to Disqualify David C. Gibbs III

By R.L. Stollar, HA Community Coordinator

On February 5, 2016, Bill Gothard’s attorney Glenn Gaffney and the Institute for Basic Life Principles’ (IBLP) attorneys at the Collins Law Firm filed similar motions with the Circuit Court of DuPage County, Illinois. These actions relate to the court case Gretchen Wilkinson vs. Institute in Basic Life Principles, in which eighteen former employees and students are suing Gothard and IBLP for sexual harassment and assault and mishandling those crimes.

HA obtained copies of the motions and related exhibits. Both Gothard and IBLP’s motions aim to disqualify David C. Gibbs III and the Gibbs Law Firm from representing the eighteen plaintiffs. They include two exhibits: sworn affidavits (testimonies under oath) and documents that Gothard and IBLP believe prove that Gibbs violated the Illinois Rules for Professional Conduct (IRPC) in his interactions with them.

The sworn affidavits come from both Gothard as well as Roger Blair, who was present when Gibbs first approached Gothard to talk about the abuse allegations. Gothard’s affidavit includes a number of personal emails between him and Gibbs that Gothard believes amount to legal advice and/or representation. In Blair’s affidavit, he claims that he witnessed Gibbs communicate to Gothard that he would help reinstate him on the IBLP Board. Blair additionally alleges that Gibbs offered to help Gothard derail the allegations against him. Blair testifies,

Mr. Gibbs spoke as if he were connected to the individuals behind Recovering Grace and had inside knowledge that would be valuable to Bill. I recall Mr. Gibbs saying, “I know how to handle it.” He stated that Bill “was wronged” and that it was unfair that “people are trying to destroy your ministry as well as other ministries.” Mr. Gibbs stated that he read allegations on the Recovering Grace website and he knew that they were false. He said that he knew how to adequately respond to “get rid of it.”

Gothard and IBLP’s motions differ in a few regards. Gothard’s motion seeks to bar the eighteen plaintiffs from using any information (including “any statements, correspondence, emails, communications, records, reports, or other documents”) collected from Gothard by Gibbs in alleged violation of the IRPC. Gothard bases this request on the legal precedent that evidence improperly obtained can be deemed inadmissible in court.

IBLP’s motion does not seek to bar the plaintiffs from using such information. However, it does contain an additional insinuation: that Gibbs did not include Gothard as a defendant in the original lawsuit in order to obtain evidence from him through deceptive means. IBLP points to an email Gothard sent Gibbs on May 30, 2015 in which Gothard wrote, “God will honor you for your generous spirit.” IBLP believes this indicates Gibbs was providing him with “support and counsel” in order to get information from him. As Gibbs is not generally licensed to practice law in Illinois, but rather is working pro hac vice, IBLP is moving to terminate his temporary license to practice law in the state due to this alleged misconduct. IBLP’s motion also specifically requests that the eighteen plaintiffs be given “an appropriate period of time to secure new representation.”

The motions, exhibits, and other relevant documents can be viewed below:

Bill Gothard’s Motion to Disqualify and Sanction

IBLP’s Motion to Disqualify and Sanction

Exhibit A: Bill Gothard’s Affidavit

Exhibit B: Roger Blair’s Affidavit

IBLP’s press release on February 18, 2016: “Motion to Disqualify Attorney David Gibbs III”

• Second Amended Complaint in Gretchen Wilkinson vs. Institute in Basic Life Principles


It should be emphasized that these motions have neither been granted or denied by a judge or court at this time. Colorado CLE Legal Connection notes that, “Motions to disqualify are far from rare occurrences” and sometimes “are nothing more than a litigation tactic, forcing attorneys to scramble to protect valued client relationships.”

HA reached out to David C. Gibbs III this morning for comment. This afternoon he issued a full statement to us denouncing the latest motions as “a desperate attempt to attack the law firm that is publicly and legally holding [Gothard] accountable for years of child abuse.” You can read a summary of Gibbs’ statement and its full text here.

9 thoughts on “Bill Gothard and IBLP File Motions to Disqualify David C. Gibbs III

  1. ethanlap February 20, 2016 / 9:39 am

    In Bill’s affidavit he states that after he understood that Gibbs III was representing some of those suing Bill, Bill thought Gibbs was still helping him and that they were working as a team. So Bill thought it was OK to have Gibbs secretly working with him but not OK for Gibbs to be secretly working against him. Whether Gibbs III did something unethical, I don’t know, but if he really did what Gothard is claiming, then Gothard was unethical in principle, as well.

    The other parts I read (not even close to everything) seem to involve Bill using all the same kinds of tactics which worked on his followers (look how successful I am; that means I’m right). He describes Recovering Grace’s mission as if he’s blowing the whistle. He sounds like a spoiled brat who’s mad he’s no longer getting away with his behavior and he thinks if he just speaks, he will get his way. But what he’s saying sounds ridiculous. This may have worked on his followers, but what makes him think this will work in a court of law?

    I think he’s that deluded by decades of yes-men/women surrounding him. For example, he points out that Recovering Grace invites people to tell their stories, as if that were nefarious. He points out that Recovering Grace edits the stories and submits them to the authors for approval, as if that were nefarious. He points out that Recovering Grace criticizes his teachings, in spite of how many people he’s helped, as if his number of followers is evidence that their criticism is invalid and nefarious. He points out that Recovering Grace’s readership took off after they started publishing stories of sexual harassment, as if that were proof of nefarious motive. To me he’s demonstrating in every turn how he twists logic and how he uses a “I’ll state the facts as if they were nefarious but let you fill in the blanks” method to get his way. Again, what makes him think what has worked so well in the organization of yes-men/women will work in a court of law? ? He sounds like a little boy trying to tell on someone, but the grown-ups saw what really happened and aren’t going to be the least bit impressed.

    Whether or not Gibbs III misrepresented himself illegally to Gothard, I don’t know. The fact that that seems to me like the one legitimate question at hand is ironically demonstrated by what would be highly unethical in principle on Gothard’s part. How would accepting Gibbs III help when knowing Gibbs III was working for several complainants be acceptable in any way on Bill’s part? If Gothard had refused his help under such circumstances, how could Gibbs III have harmed him? Bill was sneaky, it bit him in the butt, and now he’s crying foul. I think Bill has the right to cry foul in court on this one issue (if it’s true), but the public should call him out on his own sneakiness.


    • Timber St. James February 21, 2016 / 9:03 am

      I hope this commenter continues monitoring this blog, because that was a damn good read.


      • ethanlap February 21, 2016 / 9:29 am

        Why, thank you.


    • Headless Unicorn Guy February 21, 2016 / 11:49 am

      I think he’s that deluded by decades of yes-men/women surrounding him.

      Like L Ron Hubbard, he ended up believing his own PR.

      A problem common to any pointy-haired boss who can only tolerate the presence of yes-men.

      Goodbye any Reality Check.


  2. Headless Unicorn Guy February 20, 2016 / 2:09 pm

    Gibbs hath raised hand against The LOOOOOORD’s Anointed(TM) and must be dealt with.

    — favorite SCRIPTURE(TM) of Benny Hinn


  3. RW February 20, 2016 / 10:12 pm

    I happen to work at a law firm and regularly read affidavits About all sorts of matters. Reading Gothard’s affidavit makes it clear that there is a significant distance between reality and his preferred view of it and that he simply cannot comprehend that others don’t see it his way. Sounds to me like Gibbs III tried very hard to broker a deal and he took it to mean that Gibbs was trying to help him with a cover up and taking back power. When a judge reads this, Gothard will lose credibility in a big way. I kept thinking that of course he ran out of time to meditate what with all the young ladies to counsel day and night.


    • Headless Unicorn Guy February 21, 2016 / 11:44 am

      “Every now and then this [thin] crust is punctured, and the scalding lava of their hatred spills out.”
      — C.S.Lewis, Preface to The Screwtape Letters

      “Nowhere do we corrupt so effectively as at the very foot of the altar!”
      — Screwtape


    • Headless Unicorn Guy February 21, 2016 / 11:46 am

      Reading Gothard’s affidavit makes it clear that there is a significant distance between reality and his preferred view of it and that he simply cannot comprehend that others don’t see it his way.

      — intro to Mythbusters (though there it’s done as a joke)


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