G'day besty:
Sounds like a typical dub thought but wrong nonetheless.
Perhaps you could ask your "oxymoron friend" to do something new, read the scripture in context, in context of the whole letter and in context of the time in which it was written.
Ask him what was the situation of congregations that Paul was writing to?
Also point out that being organised does not call for "an organisation". I'm sure he could appreciate that his mother/wife/evrybody needs some organisation in the home but that doesn't mean the home is an organisation in the style of the WTS. And that's how the christians were meeting, in homes. Not for them the palatial Kingdom Halls with sound systems, set times, and set programs. That becomes clear from the Pauline epistles where Paul advises order in their gatherings, people talking at will.
Still, at these gatherings they needed someone to lead, someone else to care for the "widows and orphans" and so on.
Incidentally, if he's so keen on applying 1 Timothy 3, perhaps he could ask his congregation why the MS don't do what their first century counterparts did - or would that look like "good works" to him?
Anyway, suggest your friend reads up, not just from the "Insight" volumes!, but read historically and from bible commentaries - he'd certainly learn something of what the situation really was, just as I have.
Cheers, Ozzie