so first of all this case is about whether or not mr or who could be given the opportunity to pursue his claim for defamation and in the case was extension dr i submit to the court as i've said in my brief that the doctrine simply doesn't apply to this case this is a defamation case and the question of whether or not determined by neutral principles of the law we have a well established law in the state of illinois on defamation and it is that law in my judgment applies here policies of the church it simply is up to a jury to decide whether or not she's telling the truth the reverend or stella through there is a process before the church  which she could have taken advantage and she did when she charged reverend or with make an improper comments to her she had the opportunity to  said some in her opinion derogatory things about her personally and about her her looks was never examined before that process robert or didn't have a similar process there is nothing in the church doctrine that would allow him to pursue any kind of actually it's her his only recourse is to pursue a defamation so but i think that the question of whether or not that's required is long been settled in this in this country as far back as jeff jones versus wolf in one nine hundred seventy nine in that case stood for the proposition that as long as it's a matter of this nature something that's common in our locked up nation cases can be so resolved through neutral principles of law then and there's no need to examine the doctrine of the church to make that decision then the case can proceed in the circuit courts and consequently we believe that that's the proper place for this case rever nors entitle to his day in court as well he's been denied that there isn't any procedure one of those is that she's got to file a formal complaint under oath saying that the allegations that she's made against them are true why are these alleged procedural deficiencies  file anything under those that procedure on the book this month but in your brief there is a heading to bennett henderson failed to file a complaint in accordance with the requirements of the discipline committee or the discipline policy we were we were responding to arguments that we anticipated would be made in this case that he should have went through have process so that everybody understood that process was required we argued that that process required some preliminary steps on behalf of the skids which he did not follow and and did not follow through on the the the case after making the allegations she just dropped the the the action under the book of this one by freak we don't think that it has any relevance that awful to his defamation case i think we think that he should have the opportunity under the circumstances to file a defamation case and not be prohibited from doing that based on the so called sleazy asco it here's the chin not so while we argue that we only and it was not followed in this case and ultimately it was abandoned and even in this court in the circuit court this henderson abandon any of her claims against doctors she refused to participate in case management conferences shoot you she has the right answer to this complaint yet and so this place case floundered for a long period of time because we simply could not get any cooperation from her and the court in deference to her allowed many continuances what's the status of the proceeding we had not finished discovery yet before the the other side filed a motion for but that nothing has for sitting at this point pending the outcome of this appeal is that correct or incorrect no it missed miss henderson this disappeared we don't we the last time we had any contact with her was at her deposition that the bishop and elder parks republished false sexual misconduct allegations that were made to them against point thereby giving rise to defamation fos lie invasion of privacy and in and intentional infliction of emotional distress offered sufficient admissible evidence creating genuine disputes of fact for jury consideration on his claims against the a m e church defendants i need to stop here and correct  statements made by counsel the there has been no abandonment of the church proceedings there on hold the judicial committee initially found that ms henderson's allegations  founded because there was insufficient evidence they were presented with further evidence went back into session and the judicial committee actually found the allegations sustained and then proceeded with a recommendation that a trial committee be for the trial committee has been formed reverend or made some objections to some of the appointments to that trial committee and as far as i know those objections have not yet been resolved the matter is on hold but it is certainly not been  abandoned she's also not abandoned her defense of the end of this very lawsuit it's true that she has not appeared for a couple of case management conferences but she has filed a motion to dismiss the complaint agree at her failure to appear for a case management conference that a default order would be entered against her for that failure but the truck required a written order that written order was never submitted so that the default judgment was not entered there's been for themselves free from state interference or oversight on matters of church governance as well as those of faith and doctrine specifically the decisions of religious entities about the appointment and removal of their own  decisions that are beyond the reach of civil courts courts are not permitted to inquire into whether church tribunals follow their own laws and procedures in arriving at their decisions since that inquiry into the procedures that are required by canon or abstention doctrine in holding that civil courts lack subject for stiction over tort claims which arise out of alleged false allegations of perjury sexual abuse where those accusations initiated and became part of the church's internal disciplinary proceedings that's exactly the case here miss henderson has made a claim of sexual harassment against reverend or alleging that he made statements of a highly inappropriate and sexual nature to her while he was instructing her on the process for admission to regain ministry in the church in his capacity as the head of a committee responsible for screening candidates to ordain ministry her complain initiated  disciplinary proceedings against plaintiff that are still ongoing she reported the alleged harassment to other parks who is plaintiff's direct supervisor and who is the person designated under the book of discipline to receive a report of sexual misconduct against that the claims themselves could be resolved without any direct interpretation of catholic church doctrine resolving the dispute would involve the secular court interfering with the church's internal disciplinary proceedings by evaluating the of the statements that initiated and were made in the process of those her statements the dumping case which kind of cited for the first time in the reply brief is clearly distinguish contact complained of was the defendant's publication completely outside the church of information about the defendants revocation of the plaintiff's ordination as a minister the publication in duncan was made by defense trey different church and also apparently to a guardian ad litum in the plainest pending civil divorce proceeding and it was not in the context of ongoing disciplinary proceedings because the plaintiff had already left the defendant's church evidence from the test from the testimony of witnesses with personal knowledge is that any repetition by other parks of miss henderson validations of sexual misconduct by plaintiff was made exclusively in the course of thirty disciplinary proceedings under the book of discipline elder parks testified that he never told reverend larry lewis that plaintiff was the subject of miss sexual misconduct complaint that he was planning to forward to reverend lewis and then he never actually forwarded that complaint to reverend lewis because he learned before doing so that reverend lewis was not the head of the committee that handled that type of plant elder parks for the testified that he never discussed the allegations with reverend carrington but merely conclusion that plaintiff that the publication outside perjury disciplinary process did not occur if there was testimony from other witnesses that would contradict that evidence that it was incumbent upon plaintiff to bring panos reliance on neutral principles of law is misplaced while annoyed courts have intervened in certain disputes involving churches on grounds of neutral principles of law those cases generally involve purely secular disputes over ownership and control of church property or contract rights using prince neutral principles of law is not permitted where the subject matter of the dispute involves matters of clergy or church member discipline which is the case here back here the subject matter of this dispute is defendant's manner of executing its own internal procedures for investigating and addressing thirty sexual misconduct allegations the secular courts are not permitted to intervene in those matters even where the outcome of the church's proceedings may have some impact on secular rights here specter of whether defamation falsify privacy intentional infliction of emotional distress claims hand in general t principles of law don't like courts are not permitted to even attempt neutral principles analysis when the case involves a subject matter such as this where court reviews precluded the a m e church very clearly  in nature in the civil courts simply lack subject matter especially considering the trial court second alternative basis for summary judgment in favor of the a m e church defendants also supported by the record there was insufficient admissible evidence before the trial court to establish required elements of each planet's claims the claims for defamation defamation per se false by the invasion of privacy all require plaintiff to present facts of the defendant made a false statement plaintiff to a third party the trial court had before the undisputed testimony of elder parks who testified that there was no publication to any third party in this case even assuming the falsity of miss henderson allegations an important part of your position which it appears to  presented evidence supporting facts on each element of our claims therefore we have a right to a jury my impression is that the trial court's secondary basis was it wasn't a rejection of that argument  said he was guilty and talked about the case to those people we now know that lois was not part of that this was there a committee not was saying the fact that parks claim he made a mistake about that point