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DCr-Ø?-2Ø7Ø 72t?5 EPISCOPAL CHURCH CENTER
BISEOP
2009 Diocesen Report to the E¡ecutive CouncilOf the Epircopal Church
4Ð 1786
Part l.: Report of New ald Closed CongregationsFor the year ended December 31, 2009
ln compliance rvirh Cqnon 1.6.4
]N ORDER TO FACILITATE PHOTOCOPYINC. PLÉASE TYPE OR USE BLACK INK TO COMP¡,DTE THIS FÔRMSenil the orlginal to the Erecutivo Councll c./o the Research Offlce by $eptember 1,2010.
Mail To: 7'he Research OÍlce, The Episcopøl Churth CenterEl5 Second Ave., New lork NY 10017
(Makc a copy foc your fìlc.)
REPORT PRT,PAR^{TION
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Ðlocesan Reprl, Pan I D lo¿es an Report ol Co npyegatiots
A193
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 1 of 75 PageID 1119
DcT-Ø?-2Ø7Ø 1,2',:25 EPISCOPÊL CHURCH CENTER
Report of New Congrogations and ClosuresFor the year ending December 31,2009
2r2 4?r AØ2? P,Ø3
The Diocese of Ën* tl" fft'
Plesso list rll new and cloeed congregatione below (or attach a llst to thic page).
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Mail To: The Rscuch Omce, The Epiecopal Church Ccntcr815 Second evs.. New York, NY IOOI?
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A194
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 2 of 75 PageID 1120
ocT-Ø?-2ØtØ rzt26 EPISCOPâL CHURCH CENTER 2I2 4?I AØ2?
2009 Diocesan Report to the ExecutÍve CouncilOf the E Church
¡&ô
,40 1786
Part rr: operating rncome and Audited Financiar statementFor year ended December 31, Z00g
In compliance w¡rh Ceûo¡ts I.4.6(i) and t.7
IN ORDËR'I'O FACILITATE PHOTOCOPYINC, PLEASE TYPE OR USE IìLACK INK TO COMPLETE THIS FORM.
Send the original to the Executive Çouncil c/o the Reeearch Office by September 1, 2010.Maíl To: The Research O/fice, The Epìscopal Church Ccnter
815 SecondAve., New York, NY 10017
REPORT PREPARATION
BISHOP
ÇERTIFIED BY TREASURER/FINANCIAL OFFICER
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3550 Southwest Loop 820 City; Fort Worth
zip+4:76133-Texas
ing Address: Same as ebove City
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Email Address: edoftv@att.orgTax #:
817-602-39t4Robert Hicks, Diocesan Treasurer
Financial prcpared by /pr nome)
No X lf not, please give date expectcd: g-30-2010(Please complete Íorm, cven if audtr ìs not artached.)
udit Repon Anached. yes
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SþanueThe Right Reverend C, Waltis Ohl
I Date
name): RObert HicksCertified
s L^J* b '3 Ò-'¿o t r)Date
Dioccsan Report, Part 2 Dlocesan llzport of Operating lncome
A195
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ocT-Ø?-zØrØ 72t26 EPISCOPAL CHURCH CENTEREPISCOPAI DÎOCÊSE OF FORT WÕRTH
2L2 4?r AØ21 P.Ø5
Dhcesån Report of Opemting lncorneFOR THE FISCAL YÉâR ENDEO DETEMAER 3I,2OOÐ
Revenuo Us€d for From eudited financiâl
accúUnl3
or dlooêe8Adiuetmsnts
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pcymêóto horyl cqrlgrÉÊEtioni s541,S65(ådjù6tment6.
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frçm glfta or bequestsFundç uBed
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A196
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 4 of 75 PageID 1122
EXHIBIT F
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 5 of 75 PageID 1123
CAUSE NO. 141 -237 105-09
THE EPISCOPAL CHURCH, THE RT.REV. C. V/ALLIS OHL, ROBERT HICKSFLOYD MCKNEELY, SHANNON SHIPP,DAVID SKELTON, ANd V/HIT SMITH
Plaintiffs
FRANKLIN SALAZAR, JO ANN PATTON,WALTER VIRDEN, III, ROD BARBER, CHADBATES, THE RT. REV. JACK LEO IKER, JUDYMAYO, JULIA SMEAD, THE REV. CHzuSTOPHERCANTRELL, THE REV. TiMOTHY PERKiNS, and
THE REV. RYAN REED
Defendants/C ounter-D efendants
THE ANGLICAN PROViNCE OF THE SOUTHERNCONE'S "DIOCESE OF FORT WORTH''
Defendant/Third-Party Plaintiff/Counter-Defendant
THE ANGLICAN PROVINCE OF THE SOUTHERNCONE'S "CORPORATiON OF THE EPISCOPALDIOCESE OF FORT WORTH''
Intervenor/Third-Party PlaintifVDefendant/C ounter-D efendant
ST. ANTHONY OF PADUA CHURCH (Alvarado),ST. ALBAN'S CHURCH (Artington), ST. MARK'SCHURCH (Arlington), CHURCH OF ST. PETER and
ST. PAUL (Arlington), CHURCH OF ST. PHILIPTHE APOSTLE (Arlington), ST. VINCENT'SCATHEDRAL (Bedford), ST. PATRICK'S CHURCH/Rnrx¡ic\ ST ANTnPtr\V'S (-TTITRCII lRtce.l¿entidoe\
\v^ v_^rv¡4¡ÉÞv/,
GOOD SHEPHERD CHURCH (Brownwood), ST.
.TOHN'S CHURCH (Brownwood), CHURCH OF ST.
JOHN THE DIVINE (Burkburnett), HOLYCOMFORTER CHURCH (Cleburne), ST.
MATTHEW'S CHURCH (Comanche), TRINITYCHURCH (Dublin), HOLY TRINiTY CHURCH(Eastland), CHRIST THE KING CHURCH (FortWorth), HOLY APOSTLES CHURCH (Fort Worth),IGLESiA SAN ruAN APOSTOL (Fott Wotth),
VS.
AFFIDAVIT oF KATÉILEEÑ. WELLS PAGE ]
IN THE DISTzuCT COURT OF
TARRANT COLINTY, TEXAS
141ST DISTzuCT COURT
A197
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 6 of 75 PageID 1124
IGLESIA SAN MiGUEL (Fort Worth), ST.
ANDREW'S CHURCH (Fort Worth), ST. ANNE'SCHURCH (Fort Worth), CHURCH OF ST,
BARNABAS THE APOSTLE (Fort Worth), ST,
JOHN'S CHURCII (Fort Worth), ST.MICHAEL'SCHURCH (Richland Hills), CHURCH OF ST. SIMONOF CYRENE (Forl Worlh), ST. TIMOTHY'SCHURCH (Fort Worth), ST. PAUL'S CHURCH(Gainesville), GOOD SHEPHERD CHURCH(Granbury), CHURCH OF THE HOLY SPizuT(Graham), ST. ANDREW'S CHURCH (GrandPrairie), ST. JOSEPH'S CHURCH (Grand Prairie), ST.
LAURENCE'S CHURCH (Southlake), ST. MARY'SCHURCH (Hamilton),TRINITY CHURCH(Henrietta), ST. MARY'S CHURCH (Hillsboro), ST.
ALBAN'S CHURCH (Hubbard), ST. STEPHEN'SCHURCH (Hurst), CHURCH OF ST. THOMAS THEAPOSTLE (Jacksbolo), CHURCH OF OUR LADYOF THE LAKE (Laguna Park), ST. GREGORY'SCHURCH ) (Mansfield), ST. LUKE'S CHURCH(Mineral Wells), CHURCH OF ST. PETER BY THELAKE (Graford), ALL SAINT'S CHURCH(Weatherford), ALL SAINT'S CHURCH (WichitaFalls), CHURCH OF THE GOOD SHEPHERD(Wichita Falls), CHURCH OF ST. FRANCIS OFASSISI (Willow Park), and CHURCH OF TI{EASCENSION & ST. MARK (Bridgeport)
Intervenors/Third-Party Plaintiffs/Defendants/Counter-Defendants
VS.
MARGARET MIEULI, ANNE T. BASS, WALTCABE, THE REV. CHzuSTOPHER JAMBOR, THEREV. FREDEzuCK BARBER, THE REV. DAVIDMADISON, ROBERT M. BASS, CHEzuE SHIPP,DR. TRACE WORRELL, THE REV. JAMESHAZEL, THE REV. JOHN STANLEY, THE RT.REV. EDWIN F. GULICK, JR. and KATHLEENWELLS,
Thi rcl -Party Defendants/Countercl ai m ants
THE EPISCOPAL CHURCH,
Third-Party Defendant
AFFIDAVIT oF KATHLEBI.* WELLS P¡cr,2
A198
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 7 of 75 PageID 1125
AFFIDAVIT OF KATHLEEN WELLS IN SUPPORT OF EPISCOPAL PARTIES'MOTIONS FOR S ARY.IIID(IMENT
STATE OF TEXAS
COI.]NTY OF TARRANT
BEFORE ME THE UNDERSIGNED AUTHORITY, on this day personally appeared
KATHLEEN WELLS, who, being by me personally sworn, upon her oath stated:
1. My name is Kathleen Wells. I am over eighteen years of age, of sound mind, and
fully capable and competent to make this Affidavit. I have personal knowledge of the facts
stated herein, and all facts stated herein are true and correct
2. Since February 7,2008I have served as the Chancellor of the Episcopal Diocese
of Fort Worth (the "Diocese"), which is a subordinate unit of the Protestant Episcopal Church in
the United States of America ("The Episcopal Church"). I also served as a delegate from my
parish, Trinity Episcopal Church in Fort Worth, to the annual meetings of the Diocesan
Convention in 2007, 2008, and 2009, respectively, and also to the special meeting of the
Diocesan Convention on February 7, 2009 for the Episcopal Diocese of Fort Worth. I also
served as a deputy from the Episcopal Diocese of Fort Worth to the meeting of the General
Convention of The Episcopal Church in 2009 and now serve on the Church's Standing
Commission for Constitution and Canons.
3. In September 2008, then-Bishop of the Diocese Jack Leo Iker produced various
written statements advocating that the congregations and members of the Diocese should
separate from The Episcopal Church and "realign" with the Anglican Province of the Southern
Cone. True and correct copies of two such statements are attached as Exhibits L and 2.
4. At the November 14-15, 2008 annual meeting of the Diocesan Convention, which
I attended, the breakaway faction led by Iker purported by local majority vote to sever the
$
$
$
AFFIDAvIT on' Knrulpot¡ WBU-s PAGE 3
A199
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 8 of 75 PageID 1126
Diocese's ties with The Episcopal Church by purporting to replace Article I of the Diocesan
Constitution, which stated that "[t]he Church in this Diocese accedes to the Constitution and
Canons of the Episcopal Church in the United States of America, and recognizes the authority of
the General Convention of said Church," with the following text:
The Episcopal Diocese of Fort Worth is a constituent member of the AnglicanCommunion, a Fellowship within the One, Holy, Catholic, and Apostolic Church,consisting of those.duþ con^stituted Dioceses, Provinces and regional churches incommunion with the See of Canterbury, upholding and propagating the historicFaith and Order as set forth in the Old and New Testaments and expressed in theBook of Common Prayer.
A true and correct copy of the Report from the Constitution and Canons Committee to the 26ft
Annual Convention of the Episcopal Diocese of Fort Worth, recommending this change to the
Diocesan Constitution, is attached hereto as Exhibit 3.
5. At the November 14-15, 2008 annual meeting, the Diocesan Convention also
purported to adopt the breakaway faction's "Proposed Resolution for Admission to the Anglican
Province of the Southern Cone," which stated in relevant part that the Diocese "does hereby
accept the provision made by the Anglican Province of the Southern Cone, and the Episcopal
Diocese of Fort V/orth does hereby immediately enter into the membership with the Anglican
Province." A true and correct copy of this proposed resolution is attached to this Affidavit as
Exhibit 4.
6. By these actions at the November 14-15,2008 annual meeting of the Diocesan
Convention, the breakaway faction purported to cause the Diocese to join a church located in
South America, the Anglican Province of the Southern Cone, that is not a part of The Episcopal
Church. Attached'hereto as Exhibit 5 is a true and correct copy of a November 16, 2008
statement by the breakaway faction entitled "As We Realign," in which the breakaway faction
AFFIDAVIT OF KATHLEEN WELLS PAGE 4
A200
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 9 of 75 PageID 1127
claims to have "withdrawn from the General Convention" and "realigned with another Province
of the Anglican Communion."
7. On November 24,2008, the former members of the Standing Committee of the
Diocese-The Rev. Christopher Cantrell, The Rev. Thomas Hightower, Judy Mayo, The Rev.
Timothy Perkins, Frank Salazar, and Walter Virden-and Bishop Iker published their response
to the Presiding Bishop's inhibition of Iker on November 21,2008, clearly indicating that they
did not consider themselves to be part of The Episcopal Church. A true and correct copy of that
response is attached hereto as Exhibit 6.
8. On February 7,2009, the Presiding Bishop of The Episcopal Church, The Most
Rev. Katharine Jefferts Schori, called to order a Special Meeting of the Convention of the
Episcopal Diocese of Fort Worth a.fter acknowledging that, atthat time, there was "no Bishop of
the Episcopal Diocese of Fort Worth, or any quaiified members of the Standing Committee of
that Diocese." Attached hereto as Exhibit 7 is atrue and correct copy of the Notice of Special
Meeting of the Convention of the Episcopal Diocese of Fort Worth from the Presiding Bishop.
9. The individual defendants other than Bishop lker assumed their respective
positions as Trustees of the Diocesan Corporation, Trustees of the Fund for the Endowment of
the Episcopate, and members of the Standing Committee of the Diocese on or at various times
prior to November 15, 2008, by virtue of their qualification at the time of their election under
r. t , I : -L' ,- l:,- - -f - --^--:-l- ^-- -^:^-:^^
i- +L^ l-\:^^^^^olocesan ganons as tay persons IIr g(JoLr srallurlrB ur a PaII¡iu uI rrlrssrulr ru utç l-,,rurvvrn? \rr
members of the Clergy canonically resident in the Diocese, and their election to those offices by
the Diocesan Convention, Before and after the breakaway faction purported to sever ties with
The Episcopal Church and affitiate with the Anglican Province of the Southem Cone, the
AFFIDAVIT OF KÄTHLEEN WELLS PAGE 5
A201
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 10 of 75 PageID 1128
continuing local members of The Episcopal Church have continued to worship in Fort Worth as
part of The Episcopal Church and its Episcopal Diocese of Fort Worth.
10. The Diocese has consistently sent representatives to meetings of both houses of
The Episcopal Church's General Convention, including to the Convention's most recent
meetings in 2006 and 2009.
1 1. Since before I became a member of The Episcopal Church in Fort Worth in 1987,
The Episcopal Church has been providing religious services in the north-central Texas area
continuously using (1) the name "Episcopal Diocese of Fort V/orth'? and (2) a graphical depiction
of a shield (the "Diocesan Shield"). Until on or about November 15, 2008, I was aware of no
other organization that identified itself by (1) the name "The Episcopal Diocese of Fort Worth"
or (2) the graphical depiction of a shield used to identify the Diocese. Reproduced below is a
true and correct copy of the Diocesan Shield.
i. .:
I
/ri'*1
12. Through this use, the Episcopal Diocese of Fort Worth, as a unit of The Episcopal
Church, has established substantial goodwill in the name "Episcopal Diocese of Fort 'Worth"
and
in the Diocesan Shield. Those rights have been recognized by the United States Patent and
Trademark Office, which granted Federal Registration Nos. 3,820,400 (name) and 3,826,996
AFFrDAvrr or KarHr-rnN WBLLS P¡ce 6
A202
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 11 of 75 PageID 1129
(seal) for the service marks. True and correct copies of the certificates of registration from the
United States Patent and Trademark Offrce are attached hereto as Exhibit 8.
13. After the breakaway faction purported to disaffrliate from The Episcopal Church
and purported to "realign" the Diocese with the Anglican Province of the Southem Cone, that
breakaway faction continued to use the name "Episcopal Diocese of Fort Worth" and the
Diocesan Shield in connection with their provision of religious services. This has included use
and display of the name "Episcopal Diocese of Fort Worth" and the Diocesan Shield in offrcial
communications, on the breakaway faction's website, http://www.fivepiscopal.org, and on
various mailings and other publications. Attached as Exhibit 9 are true and correct copies of
examples of such unauthorized uses of the Diocesan name and shield.
14. Attached hereto are true and correct copies of the following documents issued in
conjunction with the annual meetings of the Diocesan Convention in2007 and 2009, respectively:
a. Excerpts from the Journal of the annual meeting of the Diocesan
Convention ín2007 (Exhibit 10);
b. Excerpts from the Journal of the special and annual meetings of the
Diocesan Convention in 2009 (Exhibit 11).
15. Attached hereto is a true and correct copy of the text of Canon 11 "Corporation of
the Episcopal Diocese of Fort Worth," applicable from 1982 - 1989,,and then renumbered in i989
as Canon 17 "Corporation of the Episcopal Diocese of Fort Worth," applicable through 2008, of
the Canons of the Episcopal Diocese of Fort Worth (Exhibit 12).
AFFDAVIT OF KATHLEEN WNIIS
Kathleen Wells
PAGB 7
A203
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 12 of 75 PageID 1130
STEPHANIE ROVI/ËLLrcTATT PßJC STATE tr THIIIc0rïr!t0t EÌPttc!:10-06-2()1 1
SUBSCRIBED AND SWORN TO BEFORE ME this \3^àuv of October,2010
Notary State of Texas
AFFIDA\/IT OF KATHLEEN WELLS PÄ.GE 8
A204
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TAB 1
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 14 of 75 PageID 1132
Fþ.
.Í'
+
REPORT OF THE COMMTTTEE
ON COI.{STITUTIOI\ AND CANOII{S
TO
THE 26TH ANI\UAL CONVET{TIOI\
OF THE EPISCOPAL DIOCESE OF FORT \ryORTH
EXHIBITEtÊ 3Y
A205
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 15 of 75 PageID 1133
PROPOSED CONSTITUTIONAL AMENDMENT B (Presented as D last year)
This was presented to the Twenty-fifth A¡rnuai Convention of the Episcopal Diocese of FortWorth. It was adopted last year with amendments. This is being submitted for the second
reading.
Right Reverend Sir:
O¡ behalf of the Committee on Constitution and Canons, we present the following amendment to
Article 1 of the Constitution of this Diocese, as proposed by the Standing Committee:
Existing text:
ARTICLB 1
AUTHORITY OF GENERAL CONVENTION
The Church in this Diocese accedes to the Constitution and Canons of The Episcopal Chut'ch,
and recognizes the authority of the General Convention of said Church provided that no action ofGeneral Convention which is contrary to Holy Scripfure and the Apostolic Teaching of the
Church shall be of any force or effect in this Diocese.
Proposed text:
ARTICLE 1
ANGLICAN IDENTITY
The Episcopal Diocese of Fort Worth is a constituent member of the Anglican Communion, a
Fellowship within the One, Holy, Catholic, and Apostolic Church, consisting of those dulyconstituted Dioceses, Provinces and regional churches in communion with the See ofCanterbury, upholding and propagating the historic Faith and Ordel as set forth in the Old and
New Testaments and expressed in the Book of Common Prayer,
The Comntittee on Constitution and Canons unanimously recotnmends adopti.on.
A206
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TAB 2
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 17 of 75 PageID 1135
PROPOSED RESOLUTION FOR ADMISSIONTO THE ANGLICAN PROVINCE OF THE SOUTHERN CONE
BE IT RESOLVED, that the Episcopal Diocese of Fort Worth, meeting in its 26*h A¡nualConvention, does hereby accept the provision made by the Anglican Province of the Southem
Cone, and the Episcopal Diocese of Fort Worth does hereby immediately enter into membership
with the Anglican Province of the Southern Cone as a full and equal constituent member of such
province, uttd th" Episcopal Diocese of Fort Worth does hereby accede to the authority of the-Constitution
and Cánons of the Anglican Province of the Southern Cone to the extent such
Constitution and Canons are not contrary to Holy Scripture and the teaching of the one holy,
catholic and apostolic Church.
Proposed by the Committee on Constitution and Canons
Explanation
The Episcopal Diocese of Fort Worth has resolved to remain within the family of the
Anglican Communion while dissociating itself from the moral, theological, and disciplinary
innovations of The Episcopal Church in the United States of America. The Synod of the
Anglican Province of the Southern Cone, meeting Nov. 5-7, 2007, voted to welcome into
membership of their Province those dioceses of The Episcopal Church in the United States ofAmerica who share this resolve.
Therefore the Episcopal Diocese of Fort Worth, acting by and through its lawfullycolstituted convention of clergy and lay delegates, proposes to enter into affiliation with the
Anglican Province of the Southern Cone.
EXHIBIT
IÉ
A207
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TAB 3
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 19 of 75 PageID 1137
t
Ë
o
The Episcopal Diocese of Fort Worth ' , s We eeaLLgw
Our 26th annual convention has taken actionto secure our future as a diocese.
During ú¡e Nov- t4 615 diocesan convention, your clergy and elected delegates have taken a.,
standäs faithful members of the worldwide Anglican Communion. They have heeded the call to
'contend for the fa¡th that was ohce for all entrusted to the sainb.' (¡ude 3)
What has changed?
By voting to change our diocesan Constitution and Canons, we have withdrawn from the General
Cånventi-on; dissoiiating ourselves from the moral, tieological, and disciplinary innovations of
The Episcopal Church. úe have realigned with another Province of the Anglican Communion.
This is a change in affiliation, not a change in wonhíp or doctrine.
Our Bishop, clergy, and congregations have beejn received into the fellowship of the Anglican -
Province of the Sóuthern Coie. We are deeply grateful to Archbishop Gregory Venables for this
provision, which he has made on a temporary and emergency basis, in response to the.crisis in
ihe Episcopal Church- We now look forward to the formation of an Anglican Province in NorÚr
America.
Where we stand.
We'remain true to t}e historic faith and order of the Church.
Wg remain a member diocese of the Anglican Communion.
We rernain the Episcopal Diocese of Fort Worth. The word "episcopal" identifies us as part of
the apostolic succession, with a bishop as our elected chief pastor-
We rémain in communion with other Episcopalians. We share fellowship with all those in any
Province who recognize the authority of Scripture and the faith and order of historic Anglicanism.
Everyone is welcome to worship in our churches this Sunday and every Sunday. Our liturgy re-
mains the same, our name is the same. Most of all, we remain committed to the Gospel of our
Lord and Savior Jesus Christ.
EXHIBIT
',-À.-Jh
t
A208
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 20 of 75 PageID 1138
Ê
Ð
What is the status of our clergY?
Our clergy continue to be licensed for ministry by Bishop lker. TEC benefit progtams, which may
no tong"iU" available to them, have been replaced by new gt9'!l1tu1:lce policies and a re-
iir.-"ii plan. Clergy who have established pensìon accounts in TEC will be eligible at retirement
to receivË benefìtsãarned. While these will be less than they might have had by çtaying with the
;;ù;r ionger, their new investment plan wìll provide supplemental retirement funds'
What about those Episcopatians who disagree with the decision to realign?
We know that not everyone agrees with this change. Those who dissent are valued brothers and
sisters in Christ, and'thåy are ielcome to remain In their congregations' For iome, however' it
may be necessary to separate from the diocese, perhaps permanently- ln a few cases' it rnay be
the'will of a majorìty oithe members in a particular parish to remain in-The Episcopal Church'
Wh.r" this is the case, the Bishop, Standing Committee, and Board of Trustees hope to work
with the rector and vestry to corne to a muiually agreeable separation and settlement of property
issues without resort to lawsuits or other hostile actions
what response should we expect from representatives of the General
Convention?
We expect a number of announcements in the days, week, and months ahead. Among these
-ay bå plans for a new General Convention-member diocese in this 24-county area. There may
b. íawsuits testing the ownership of our properties. And action may be taken to remove our
Aitttop and clergy"from their potitiont in ministry in the General Convention church' But such
aaion will haveîo practical effect, sín.u they wiil already be ministerìng under the authority of
another Anglican Piovince. These developrnents may generate news headlines, and they may
.urra ,orn"".onfusion, but they will not prevent us from going forward in mission as a diocese'
What next?
On Nov. 24, Bishop lker will meet with the clergy on the topic of "Moving Forward - Life After
TEC." Other events for clergy and lay people will be announced in the weeks ahead. Please con-
tinue to pray for our diocesle', for all 'Episcopalians,
and for the Church throughout theworld. Let
us pray fbr Cod's guidance for ourselves and for the leadership of our churches and diocese. Let
ur ruuk the peacelhat passes understanding. Let us re)oice in God's saving grace and cont¡nue to
carry his message of love and salvation to the world-
The actions of our 26th diocesan convention assure us of: ourfuture as traditional Anglicans. We are now free to carry out our
diocesan m¡ss¡on, "To equip the saints for the work of ministry."
ilECUSA 001567
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THE EPISCOPAL DIOCESE OF FORT WORTH2900 Alemeda Street
Fort Worth, TX 76708
877-244-2885 voice
877-244-3363 fax
www.fivepiscopal.org
THr Rr. Rrv. Je,cr Lro IrcR, Bishop
November 24,2008
RBsporusES To ATTEMPTED INHIBITIoN oF THE Blsnop
FORT WORTH, Texas - A letter of inhibition and supporting documents were issued Friday, Nov.21, from
the office of Katharine Jefferts Schori, Presiding Bishop of The Episcopal Church, to the Rt. Rev. ]ack Leo
Ikeç Bishop of Fort Worth. However the inhibition is of no force or effect, since the Bishop and Diocese,
meeting in annual convention, constitutionally realigned with another province of the Anglican
Communion on Saturday, Nov. l-5, and are now constituent members of the Anglican Province of the
Southem Cone. Documents to this effect have been made public. Consequently, this attempted inhibition
will not deter the Bishop from the continuance of his ministry.
Two responses are being issued at this time. From Bishop Iker:
Katharine Jefferts Schori has no authority over me oï my ministry as a Bishop in the Church of
God. She never has, and she never will.
Since November 1-5, 2008, both the Episcopal Diocese of Fort Worth and I as the Diocesan
Bishop have been members of the Angiican Province of the Southern Cone. As a resulÇ canon-
ical deciarations of the Presiding Bishop of The Episcopal Church pertaining to us are irrele-
vant and of no consequence..
The Rt. Rev. ]ack Leo IkerBishop of Fort Worth
From the Standing Committee:
The Standing Committee of the Episcopal Diocese of Fort Worth is a member of the Province
of the Southern Cone as of November l-5, 2008. Bishop Iker is a member in good standing of
the House of Bishops of the Province of the Southern Cone.
We wonder by what authority the Presiding Bishop of the Episcopal Church in the United
States presumes to inhibit a bishop of the Province of the Southern Cone. We do not recognize
IÁ u
EXHIB IT
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Noaember 24,2008 page 2 of 2
the authority of the Presiding Bishop over us. We regret this illegal, unconstitutional, and
uncanonical attempt to interfere with the rights and ministry of a diocese of another province of
the Anglican Communion. We call upon her to desist from any further actions in our diocese and
that she refrain from any further border crossing'
The Rev. Dr. Thomas HightowerPresident, Standing Committee
The Episcopal Diocese of Fort Worth consists of 56 congregations. The major cities in the diocese include Fort Worth,
Arlingtorç Hurst-Euless-Bedford, Wichita Falls, Grand Prairie, Rictùand Hills, Brownwood, and Stephenville, Texas. The
Rt. Rev. jack L. Iker has served as the third Diocesan Bishop of Fort Worth since 1995. The diocese "tioys
companion
relatior-rships with the Dioceses of Northem Malawi and Northem Mexico,
-30-
Contact: Suzanne GillDirector of CommunicationsThe Episcopal Diocese of Fort Worthhs gill@fwepiscopal.org
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THT EpISCOPAL CHURCHThe Most Reverend Katharine Jefferts Schori
Presiding Bishap and Primate
Notice of Special Meeting of the C.onvention of the Episcopal Diocese of Fot lVoñh,
Saturday, February 7 , 2009, Trinity Episcopal Church, Fort 'tflorth, Texas
There being at this time no Bishop of the Episcopal Diocese of Fon 'Wonh, or ^tty
qualified
memben of the Standing C-ommittee of that Diocese, as the Presiding Bishop of the Episcopal Church,
in consuhation with the Steering Comminee of faittrful Episcopalians of that Diocese, I hereby give
notice that at 1:30 p.rn CST on Saturday, February7, 2009, at Ttittity Episcopal Church, Fort'Worth,
Texas, I shall cail to onier a Special lvfeeting of the Convention of that Diocese.
The purpose o{ this Meeting will be the election of a Provisional Bishop of the Diocese.
Thereafter, the Conv.ention is e4pected to proceed to the election or appointment of memben of the
Standing C.omminee, Executive Council, and other officen of the Diocese; adoption of a budget; and
corsideration of resolutions relating to recent puqporced amend¡nents of the Corstitution and canons of
tlre Diocese as well as other resolutiors relating to the orgenizatio¡ and governance of the Diocese.
All qualified clerical and hy delegates to the Convention are u¡ged to attend. Giteria for
qualification and a proposed agenda for the meeting will be provided in a subseqr:ent notice.
The meeting will be open to the public as space permits.
For further information, please refer rc hnp://wwv¡.episcopaldioceseforwonh.org or contect
eirher of the CoCtrairs of the aforementioned Sæering Commitæe: 'Waker C-abe (w¿lter.cabe@att.net)
and the Rev'd Gnon Courtland Moore (courtmoore@verizon.net).
flhe Most Rev'd) Katharine Jefferu Schori)OffI Presiding Bishop of the Episcopal Church
THE EPISCOPAL CHURCH CENTER
h
ËÉ 'l
EXH IBIT
815 Second Avenue New York. NY 10017-4503 USA . 212-716-6276 a 8OO-334-7626 e www.episcopalchurch.org
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.6$ttel årtstÊß sf Hwettw
Reg. No.3,820,400
Registered July 20, 2010
Int. Cl,:45
SERVICE MARK
PRINCIPAL REGISÎER
@níteù #tutes lþutent snì @rnhemnrh @ffíce
The Epíscopal Diocese ofFort Worth
Epts coPAL DiocESE oF FORT }VORTH (TEXAS U N IN CORPORATED ÀSSOCIATÍ ON)
3550 SOUTHWEST LOOP 820FORTìVORTH, TX'16133
FOR: RELIGIOUS SERVICFS, NAMELY, MINISTERTAL, EVANCELICALAND MISSIONARY
SERVICES, rN CLASS 45 (U.S. CLS. 100 AND l0l).
FIRST USE 6-l-1983; IN COMMERCE 6-1'1983.
THE MARK CONSISTS OF STANDARD CHARACTERS WMHOUT CLAIM TO ANY PAR.
TICULAR FONT, STYLE, SIZE, OR COLOR,
sEc,2(F).
sER. NO. 7't-748,064, FILED 5-29-2009.
HAI-LY LAM, EXAMiNING ATTORNEY
ft;,'î.LwDir(rtor of lh¡ lln¡rcd Slllq Pdcn( Ðd'ÍÉdcmük OflìEc
-A213
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REQUIREMENTS TO M,A.INTAIN YOUR FEDER.ALTRADEMARK REGISTRATION
WARNINGI YOUR REGISTRATION \ryILL BE CANCELI,ED TT'YOU DO NOT FTLE TTIEDOCUMENTS BELOW DURTNG TTIE SPECTFIED TIME PERIODS,
Requirements in the First Ten Yearsã
What and When to File:
c Fírst Filing Deadlìne: You must fìle a Declaration of Use (or Excusable Nonuse) between the
5th and 6th years aftertheregístration date. See 15 U.S.C. $$1058, 1141k. If thedeclaration is
accepted, the registration wilI continue in force for the remainder of the ten-year period, calculated
from the registration date, unless cancelled by an order of the Commissioner for Trademarks or a
federal court.
I Second FìIìng Døadlíne: You must fite a Declaration of Use (or Excusable Nonuse) and an
Application fo¡ Renewal between the 9th and iOth years after the registration date.*
,1¿¿ 15 U.S,C, $i059.
Requirements in Successive Ten-Year PerioilstWhat and When to File¡
You must file a Decla¡atíon of Use (or Excusable Nonuse) and anApplication for Renewal between
every 9th and lOth-year period, calculated from the registration date'+
Grace Period Filings*
The above documenrs will be acceptecl as timely if filed within six months after the deadlines listed above
with the payment of an additional fee.
The United Ståtes Patent and Thademark Office (USPTO) will NOT send you any future notice orreminder of fÌrese filing requirements.
*.ATTENTION MADRIÐ PROTOCOL REGISTRANTS: The holder of an international registration with
an extension of protection to the Unitecl States under the Madrid Protocol must timely file the Decla¡ations
of Use (or Excusable Nonuse) referenced above directly with the USPTO. The time periods for filing are
based on fhe U,S. registration date (not the international registration date). The deadlines and grace periods
for the Declara¡ions of Use (or Excusable Nonuse) are identical to those fot nationally issued registrations.
-gee 15 U.S,C, S$ i05S, I 141k. Howcver, owners of international registrations do not frle renewal applications
at lhe USPIO. Instead, the holder must file a renowal of the underlying international registration at the
International Bureau of the World Intellectual Property Organization, under Article 7 of the Madrid Protocol'
before the expiration of each ten-year term of protection, calculated from the darc of the international
registràtioi¡ See15U.S.C.$1141j. Formoreinformationandrenewalformsfortheinternational registration,
see http://www.wipo. inlmadrid/en/.
NOTE: Fees and requirements for maintaining registrations are sulrject to change' Please check the
USPTO website for further information. lVith the exception of renewal applications for registered
extensions of protection, you cân file the registration maintenance documents referenced above online
at http;//www.uspto.gov.
ö
Page;2/RN #3,824,400
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Wuw66sW @ewË,ø,ffi ætr ffiwæffinífeb St*teg frþetemf ømÞ @rsber¡tsuk @ftÉee
yffw
.ar
x.¡fti¡7
Reg. No. 3,826,996
R"egisÉened ,{ug. 3, 2tl0 FoRr wot{rt{, rx ?6 t 33
lrat. Ct.:45
SERVTCÐ MÀRK
FRXNCTFAT. R.ÐGTSTT}R
EPTSCOPAL DIOCESE OF FORT ÌVORTH (TEXAS UNINCOIIPOIIATED ASSOCL{rlON)3550 SOUTHWEST LOOP 820
FOR: RELICIOUS SERVICES,.NAMELX lvtlNISTEIIIAL, EVANGELICÀL^ND MISSTONÁI{Y
SERVTCES, lN CLASS 4s (U.S. CLS, r00 AND l0l).
FIIìST USE 6-l-1983; IN COMMEIICE 6-1-1983.
NO CLAIM IS MADE TO THE E}íCLUSIVE RTCI.IT TO USE "Iq83", ÀPART FROM T].IE
MARI(AS SHOWN.
THE COLOR(S) BLACK,'WFIITE, SILVER, GOLD, GREEN,.MAROON, ORANCE'AND BLUE
]S/ARE CLÀIMED AS A FEATURE OFTHË MAIIK.
THE MARI( CONSISTS OF A LARCE VERTICAL ELLTPSE IN WHTTE CONTAINING A
SECOND VERTTCALELLIPSE IN V/HITE BETWEEN WHICH ELLIPSES APPEAR IN BLACI(FONT THE WORDS "TFIE.SEAL OFTHE EPISCOPAX DÍOCESE OF FORT \\TORTH" WHICH
APPEAIì ABOVE TWO SMALL CROSSES AND TI-TE YEAR "1983" WI'IICFI ARE ALSO INBLACÍ( FONT WITH TI.IE 1NSIDE VERTICAL ELLIPSE FUTTTHER CONTAINING A \,VH¡TE
TJISI-IOP'S MITREwlTH COLD AND BLUE BANDS UNDER WHICH ÀPPEARS A SHIELD
WITH A GREEN SQUARÊ INTI{F, UPPER LEFTQUADRANTOFTÍIESI-IIELD UPON IYHICI.I
IS EMBLAZONED A COLD AND BLACI( COLORED CRIIIFIN ÄND WITI.I MAROON
COLOIìATI,ON ON TI-IE IìIGHT QUADRANT OF THE SI.IIELD EXTENDING I¡: A BANDACIIOSS'l'HE À4IDDLE PART OF TIìE Sl-llELD BELOW WI{ICH APPEARS AN OR¡\NGE
BAND ACROSS T}IE SHIEI-D WITI-I FORTI{ESS BAÏTLEMENTS OUTLINED IN tsLACI(
AND UPON VI/HICH IS ËÌVItsLAZONED À BLACI( I.ONGHORN STEBIì .BELOW WI:IICI{
APP¡]ARS A RLI,IË BANI) AT THE BOTTOM OF THE SHIELD UPON I/IiICH IS EM-
BLAZONED TWO WAVY 1À/IllTE LINES AND A V/Í'IITE FIVE POINT STAR AND IJ.EHINI)
THE SHIELDAPPEAIìS A GOLD AND BLACIT COLOIìED J(ËY AND A SILVEI{AND I]LACI(COLORED BlSl-lOP'.S STAFF WITH A WHITE AND MAIIOON BANn*El( UNDERNEATIJTIJE SHIELD UPON WfIICH'TIìE WORDS ''LOS tsI{AZOS DE.DIOS'' ÀPPEÀIì fN BLACI(FONT.,
TH.EENCLISI.ITIIANSLMION OF ''LOS BÍ{AZOS DE I)IOS'' IN THE MAIì,J( JS ''THEAIìMSOF GOD''.ffi;T"LW
l)irdtor ofil,. Llnitcrì Slrlcs I'ôlcnt ¿nd'l rudc,nxÍli Oíict
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Reg. NO. 318261996 sEC. 2(F) AS ro "rHE EPISCoPAL DI9SESE oF FoRr woRTH'
sËR. NO.'t1 -7 48,164, FrLED 5-29-2009,
I{AI-LY LAM, EXAMININ6 ATTORNEY
Page:2/RN#3,826,996
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I.H F ËPISCCIP¡rL DIOCESI: C)]:: FONr \A/ORTI-J'Ijrc I{¡. }\cv, Jack l-. Ìkcr, D.D., I}ilny of]ort \\?ortlt
Trm Brsr-ror,'s llolrans AxNu¿1. Appnll
Ll¡rur'?tL{.l
".[¡1¿jl ¡r/-1,ori ttusL givt' ct-< 1'¡¡1lr¡71'¿, rnade tr¡, )loilr tnìtrc\, ttot rrlucl¿ntlt' or rmdu cottrixtlsitttt,
jol Go,ì lovc: a cbcu'ftil gìvc.r." l.l (.,orítúhi:L.ts 9:7
I.)¿ur Fricnc{.s in Chri.sr;
.fr is ].,c¡r cr¡i:c rtgai¡, ;¡¡rct tlris is rlrc ¡i¡¡c fer nry atrtrutnl a¡rpcal ro c'rct'y fiol¡"t'lrolcl ilt otu'
djt.¡cc'.se firr sup¡rorr of the "llishopJs Dclllars" cirm¡ri¡;ig¡¡. Plcasc assist tnc iu t'esfror¡clirrg ro rl'rc
rla.r:1'nec<fs th;¡r,:onrc ro rì-r\r ¿lrt(ïrrion clrrring rhe courst- of tbe 1,ex¡ frctnr a valicry of sour,--cs
\ilur gifì u'í11 be o l¡lessing üo ser]lrorìc rvlro looks to flrc irs thcir' (lhíef Pasrot in rime clI
firurnt:i,rl nectl. It u'ill ¡rlso cl:rablc nre to provicle lìrr a rurnlbct of nrìnistrl nec.{s rha¡ at'c nor
inclu."led ìrì cllc ånr1uâl buclget oÍ rhc dioccsc.
']'his comirrq fill, ive rl,ill havcr lir,e iirll-tiruc scurínarians fì,onr ortr clic¡cese, sonre oF rvlionr are
rnarriecl u,itl.r cI¡ildlcu. -l'his
frrird il; onc \\,a\j I hav¿ to assist rhcm in urcc'.tirrg tlieil unitluc
neec:ls. In adclirion,.spcc:ial ¿:r.s¿s ir¡ clerr-g1. f¿¡,tj¡¡,,s ar-c clficn br:,rugJrt t<> trv a¡lerrrit-¡n, an.:l ir is
,rlu';ry-s good for nrc lo irc: ltblc' to assi.sr them .[inanciall¡,, as r'"'cll :rs sptiriuulrllr'. Along rvith rlic
ßisho¡t',s f)isr:r¡,:.t:irlnirrt, litrn.l crfirclitrgs reccíir:c{ ¿r the cillitr olm}'¡ltu''r-l'll yisir¡rlíou to yç1¡t'
chtrrch, rhis anrrual. .[,enrcl'r apFc¿[ is an inr¡rorcar].f: rcsol.rr:ce ro ¡.r'rlvic{c firr nran¡, difi?r'crrr llcec[s.
PLI¡^sc uscr rhc c,l.:losco{ cnt clopc lor your gifi to rhis ),¿arìs "Bishopis Dcillars" canr¡raien.'l'[ienl<
vt,ri in acir.¿rncc fì:i hcl¡rìlr.l ro a,ssist orlrcr:s in ¡hc n,r¡nc .rf rile L,ordJc.srrs Christ. Nfay ¡,ori h'rvc a
blcssccl Lcnr, :rn<ì nr¿r). r'our qiving incr:casc vr>ut'.iori
Ir:aithfrrfi y in Chrísr,
rÞ-r,4 M4Tlie Rr. l{cu-Ja.{< I-,eo lkcr:
ßisho¡. oi Fort \\'orrlt
lìru:lo¡iu rc'
2900 .Alemedr. Forr \Vor¡ir,'IX7l¡lOti lituu' 817.244.2885.í¿x 8l7.?.44,.1363 vnnv.Âvcpiscopal.org riiocesepÊvcpiscopal.org
" EE r ipp ing the s,zi n r.fitr n h t ii tt1,"
r
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FORWARD MISSIONTînA publication of thc Episco2al Dioc¿se of Fort [4/orth Pentercst 2010
,{nÁppeølfrom the Bishopfor the
Lrcar ÐBEpNsB FuNp
Dezrr F'aithful Parishioners,
It is time for everl loyal parishioner in the Diocese to step forward and make a contribution to
our Legal Defense Fund. Every gift matters - er¡ery donation is important! Our goal is to raise a
minimum of $ L million to cover our legal fees as a resr,tlt of the litigation brought against us by The
Episcopal Cllurch and its local supporters. At stake is everything we have as a Diocese - or¡'nership
of Camp Crucis and the Diocesan Center, our churches and property, our bank accounts and
investments, our clergy and our Bishop. TEC wants it all!
As 1,6¡ knorn', b], a margin of B0o/o our 2008 Diocesan Convention voted to remove all
references to The Episcopal Church from our Constitution and Canons. TEC tvas formed as a
r¡oluntarl association, and it remains so foday. A diocese can withd¡arry from TEC by a Convention
vote, just as it joined TEC by a Convention vote. However, the minority group who disagreed with
this decisiorr claimed that we did not have the legal ríght to do so and decla¡ed that all our church
properfy actually belongs to TEC. Tiiey held a bogus meeting tn 2009 rvhere the1, attempted to
replace ail the legitimate officers of the Diocese and the Corporation of the Diocese, and they later
decialed all our ciergy were deposed from the ordained ministnr It is this bogus gror"rp ofrepresentatives who have sued us, the real Diocese and the real Corporation, demanding that we
turn over all our properfy and assets to theml
While thìs fairy tale may have initially conf-¡sed the Ta¡rant County trial court, the Appeilate
Coi.rrt was not confused and ruled on June 25th fhat these indir.iduals could not sue us in the name
of the Diocese and of the Coryroration, but only as individuals. They have now refüed their suit in
their or,vn names. In the end, we âre confident that the Texas coults rvill enfor-ce our state lalt's
governing corporations and property ownership'
In addition, u,e have been dragged into a second court case (this one in I-Iood Counq') u'here
TÐC supporters ale trying to prevent St. Andrew'.s Episcopal Church in Fort Worth from receiving
funds left to them in a bequest bJ, a parishioner. TEC wants the tnonel¡ sent to them insteadl
I am saddened by the necessiÛ' of having to defend ourseh'es in these lawsuits. We did not
initiate this litigation, and in fact, rve have done evcrl'rhing we could to avoid it' Frorn the
begiuning, we asked the disenchanted minority to join us in developing a reasonable plan to divide
the properry and assets of the Diocese so that we all could continue to carry on God's work without
the distractions created by litigation. In fact, the Corporation deeded their church Properq/ to
Tiiniq' Church in Fort M/orth, St. Luke's in Stepirenvilie, and St. Martin's in l(eller, because these
parìshes wished to remain in TÐC. We rvere in the process of doing the same for others u'hen TEC
cottt. on þage 2
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filed suit against us, demanding all of our properС, The Presiding Bishop ofTEC has insisted that
TEC must have ALL of the assets and propertl, of our Diocese. Given that position, we have had
no alternative but to erLga:ge legal counsel to protect our interests and to bring this process to an
end at the earfiest possible tirne.
It is the straregy ofTtrC ìn all of its litigation to make it as expensive as possible for those ìtsues, so that they eitber give up or are unable to continue the process of lìtigation.'Ihe onl1'wa)¡we
have been able to defend our congregations in court so far is through the generous suPport ofDickandl\4arsland Moncrief.To date the l4oncriefs and afewothers have contributed about $900,000
to our defense, and the litigation costs continuel I feel the time has now come fo¡ our legal fees to
be shared by all concerned members of this dìocese, not just a few; and for that reason I am asking
for your support.
Please consider making a special gift to this fund, wlúch will qualifl, as a tax-deductible
charitable donation to the Diocese. Though one-time gifts are great, it rvould help if 1,o¡ .outd
piedge a certain âmoultt over a period of several uteeks or months. M/ith l'our help, we are
optimistic al¡out our goal of securing our legal position as a diocese, but it is a rrer)' expensive
process. In the event that our funds are not exhausted before litigation ends, the balance will be
di¡ected tou'ard the mission of the Church.
Thank vou for considering this need. Do uphold this n'hole campaign in yor"rr prayers!
Faithfuüy in Christ,
4-Y,4'd-W^/i
The Rt. Rev. Jaclc Leo lkerBishop of Fort Wordr
Questions and ¿{.nsrlers about the litigøtion
How did this controversy end up in courtl Aren't Christians supposed to bc able to solve their differences
without resorting to lawsuits?
We a¡e in court as defendants, in a suit brought against us by The Episcopal Chu¡ch an<l their lt¡cal
supporters. Yes,'"ve offerecl out-of-court settlements and even deeded church properq' to them, but this was
not acceptable to the other side. Thel' dont want just what's theirs - thel' want r¡'hat's ours as well!
M/hat's at stake if we lose iu the courts?
All church properr\¡ and assets r¡'ouid be piacecl under the control ofTEC. Our clergy and Bishop would be
removed from the churches and replaced b1'TEC loyalists. Oniythosewho sr¡'ore aliegiance to the revisionist
docrines and practices ofTEC could hold an)/ office. Firia1l1i thel'wou1d need to se1l some of the properry
thel'acquired in order to recover their own legal expenses
2 For¡unrd In Mission - Pentecost 2010
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Qorcstions ønd -4nszu€r's, cont
Florv much has tlús lawsuit cost us, and hor¡'much nore it is likely to requireì
Since the litigation was filed agrLinst us in Âpril 2009, u'e have spent close to $1 rnillion in attornel' fss5.
Considering that the case rvill likely end up before the Texas Supreme Court, even with our attorneys
reducirrg their hourlv rates as lor¡' as
possible, we can anticipate at least an
additional $1 million to see ittirrougçh to a c<¡nclusion. Withroughl1, 8,000 households in the
diocese, this arnottnt could be raised
through individual contributions of
fi725 per fanrìl1', at a rø.te o{ 525 per
month over fir'e months.
The chart at right b¡eaks do'"r'n the
Number ofPledge Payments
Arnount ofEach Payment
Number ofPartìcipants
PlcdgeAr¡ount
5 fi258,000 $125
) $504,000 fi250
72 $841,000 fi1.,000
L2 $11 1750 $1,334
$1 million goal, shou,ing average pledges needed depending on the tlrtmber of participating households lfeach household contributes as it is able, the goai can be reached in a timel1' wa1'.
Who has paid the bills for all this?
Dick ar-rd Marsiand Moncrief have stepped fo¡r,r'ard and paid nearil' ¿[] of this, but this one famiJy shoulcl not
be expected to bear tbe entire bur'den f<¡r the rest of us! Everl'parishioner siroul<l help bear sorne of this load,
and that is u'hywe have launched this Legal Defense Fund Á.ppeal. It is oul battle, not someone else's!
Be assured that no funds have come fi'om church assessulents or the diocesat budget. The mission work of
the dìocese continues. While we have r¡ade cuts in spending as t]ìese challenging economic times have
clemanded, we hat'e not done so to clivert funds for litigation.
Horv many people support the TEC position, and hou'rnan¡ starrd \t'ith Bishop lker?
It is roughly a20/80 s¡rlit. The convcntion delegateswhovoted to separâ.te f¡omTEC in 2008, the number
of congregations aligning with Bishop lker, and the average Sunday attendance of those remaining with the
diocese siuce the split are a solid 80%o of the total'
Wlry should we give money for ia'wyer fees, when we would rather support the ministry of the Church?
Tlre lauyers u,e have hired are devout Christians who see the battle we âre engagecl in as spiritualw'arfare,
Defending the truth of the historic faith and practice of the Church is part of our ministrl' as a cliocese. Our
legal tearn is atternpting to protect onr chi.rrches from a hostile takeover, and their fees a¡e well belo¡¡'the
normal attorneJ,fees. No larvyer gets rich on court cases involving chrtrch controversies. Without this
representation, rve'woulcl be overr¡¡heinred by the other side. Our attorne,r's believe in lvhat we are standing
up for as Christians, and they deserve faír compensation for their sen,ices.'lhey see theil professioual rvork
as part of their minìstnr
Hor¡' can we learn moreì
Atte¡d yor,rr deanerl,'s Pre-Convention meeting in October, or ask your priest for an update. Also, check the
diocesan M/eb site, gv-w.fwepiscopalorg, for regLrlar updates.
Foru,arrl In tl(issiott - Pentecost 2010 3
A220
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 36 of 75 PageID 1154
Litigation Persp ectiveFRoI4 ouR I,DAD ATToRNEv, J. St-trlnv Sl-rnnpa
Thc Jitigation that The Episcopal Church has fìlcd in Târrant County and Floocl Counlv needs to be put inproper perspective fol vou¡ understanding and to obtain a sense ofpeace in your heart.
Keep these thoughts in mind as you pray:
First, the lìtigation is contrary to 1 Corinthians 6: 7-7. Thus, God is not the autho¡ of 1'he suit
although I-Ie has allor¡'cd ìt to happen.
Second, tire response to the suit by).uur leaders is b¿sed on sound Liw that, íffollorved by the
conrt, sirould result in a defeat for those bringing the litigation.
Tlúrcl, The Episcopal Chlrrch is asking for proper:ry that it did not bnv nor does it have any legal
or ecclesiastical i'igirt to receive.
Fourth, your leaders lvho have been sued have conducted themselves in accordance with law,
pertinent ecclesiastica.l documents, and the Scriprures.
Fifrh, the response ofy'our leaders seela r:o relieffrom the court that is contrar;¡ to anT Scripnrre.
Sìxth, the resporlse of I'our leaders to tirose suing them will be made in a Christ-honoringnranlre! vvhether in or out of coult.
Seventh, pral'for those representing your leade¡s tirat God rvill lead and guide them so that Heis glorified in all that is clone.
Eighth, pray for the leaders ofThe Episcopal Church and the <¡thers wh<: have brought the suit
that they will hear and obelr ra'þ¿1 God would have them do.
Ninth, pral' that your leaders and all r¡'ho support them will be a good testimony to those who do
not know the Lord who are watchir:g the litigation so these lost people will not be dis-
couraged from seekingJesus. This includes speaking no er'il ofthose u'ho have brought the
suit.
Tenth, pral' for each courr before r¡'horn the suit goes, that God will protect each from any
influence other than His, and that justice will be the basis f:or e\¡ery ruling.
Heading our legãl team.
WJ. ShelbySharpe. Born'i940 Fo¡t'\Ã/o¡th,Texas. Education: University olTexas (8.Â. I962,J.D.1965); Director, Fort
lVortlr-Tarraut Count¡, Bar -Association, 1972.-7 4. Chair; State Bar of Texas Comrnittee on Aclministration of.Justice, 1992-
94. Practice areas: [4iedia Larv; Irrsurnnce Defcnse; Constirutional.Litþation; Complex Litigation. Member, Christ Chapei
Bible Church, Fort Worth.
R. David Weaver. Born 1950, \Ã/aco, Texas. Education: Baylor Universi.,(I.D.1982). Practice areas include Alte¡native
Dispute Resolution, General Business arrd Cor¡mercial N{atters, lncome Tax and Properry Tax À4atters, h{enrber, St. Alban's
Episcopa.l Church, Arlington.
Scott A. Brister. Born 1954 Waco, Texas. Eclucation: Duke Universig, (B.A'. 1"97.7), Han,ard Lar¡' School (J.D. 1980). Judge,
234th District Courr, 1989-2000; Texas Cou.ts of Appeals, 2000-2003; Texas State Supreme Cou¡t, 2003-2009. Currerrtly in
prilate practice; board certified in civil trial and civil appellate lar¡,. Metnber, Redeernel Presbr'¡eritn Church (PCA), Austin.
4 Forword In Mission - Penteiost 2010
A221
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DIOCESAN CALENTDAR _ PENTTECOST 2O1O
g0I9¿ tasal 'tlLto/l4 /'t(/¡{ 'upawa¡y 6967çto1p1 t.Lo¿ -{o asatozq 1ødotsldg ,rl¿
(8tS) 'oN rrurãdsExaJ'qìroM lroJ
CIVda5ciso¿'gn
'3:g rgorduo¡
NIOISSTW"!0dv^AuoJ
.,1.i ., _.i
'i::i'-
zlt.rgurt
S4ttcnthn'
8/29
8/31
9/5
9/6
9/9
9/11,
9/72
9/18
9/19
9/20
9/21-23
9/25
9/26
9/27
9/29
S'r. VINCEN-| 'S CATHEDRAL, Bedford
10 a.m. Board of Trustees
ST. ANDREW'S, Grand Prai¡ie
Labor Day l{-oli<lq'-.Dioman OJ,fices tloscd
1:30 p.n. Executive Council
St. Anselrn',s School ofTheolog.t, bcgins acadcnric yca¡ St. Pcter U St. Paul,,4iìtzgton
ST. MATTI{IAS,Dallas
Frmily Ftrn Fcst, CanV Cruei.s
ASCENSION & S'l'. X4ARK, \4¡ise County (Bishop lVantland)
9:30 r.m. Clergy Day rvith Archbishops Robe¡:t Duncan and l4ouneer Anis
ÂRDF Board ofTiustccs Meeting, St. rlndrew!, Fort l4l¡or¡h
9:30 a.rn. Dry olDiscoverl,t St. Peter U St. Paul,.l)rlìngton
ST. PETER & ST. PAUL, Arlington
1:30 p.rn. Standing Committcc
7 p.rn. Ordination of Andrew Petta to the prìesthood, ,St. I'ìnrcnt'.s, Bedford
þbru¡rd It ìVIission, r publication of the l)ioccse of lort \,\'brth, is distributcd slr tirncs a lcarThc Rt. Rev.Jack L. Ikeq publìsher; Suzannc Gill, eclitor (sgill@fivepiscopal.org)
Offirts îl naìlThe Episcopal Dioccsc of Fort WoLth,2900 Alcneda Strect, Fort M/orth, Tcxas 76108
Tcl cThonc 817.244.2885 fa x 577.244.3363 umr'.fivepiscopal.org
A222
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 38 of 75 PageID 1156
F# #ffi Mrs$r#þ{¡f¡þ¡rå.içrsflorr t{ tfu fpà**ps,f rÏidr.rse 4Éf}øw 'S&rl$'
I4títhfizith, hope, and loøe
C fu urcÉe e s fuæLpiwg {æmlxhvæs
tkw wnrgþr þzns å- t i a% e s
On Thursdap the food comes in. On TuesdEæ itgoes out again. Week in, week out, that has been
the routine at Christ the King, Fort \Morth, for a
dozen years or more. The churrch's food bank min-istq, is housed in a portable building on the west
side ofthe parking lot, walking distance from the
bus stops on Camp Bowie Blvd.
The parish-run minisry is powered by the tíme,
talents, and t¡easure
of the ccngregation,
but principally by
Andy and Judy Per-
rier, who have made
it their labor of love.
Eastertide 2009
work. On a recentTuesday three of the first 11
families served were new to the food p^ntry.
Demand for hot meals and grocery assistance is
growing in rnany areas ofthe diocese. Since September, St. Mad<'s, Arlington, has operated a soup
kitchen everyThursday at lunchtime. (For tnore
aùou t this, see frup is c op a L org.)
St, Simons Church in southeast Fort Worth has
been a leader in the cooperatirc SEARCH (South
East Area Churches) ministry for 15 years. The
chu¡*i has been the ministry's No. L donor for 12
ofthose years, contributing cash and grocery items
everyweek, plus famil¡sized food baskets at
Thanksgiving and other gifts at Christmas and
Easter. A member of the parish curæntly serves as
president of the SEARCH board. "The needs
conthrued on page 3
Daøid WcAa; Eloìse Patla, and Sandy Kruse (at rìght -baggìng fotatoes on St. Patticþ\ Day) prcparefoodfor needy
families uho conte each Tuesàay to the snrall tuilding at the
rcar of the chutcù pnpertl. In February Christ the Kingsercred 93 househoÌds, rePresetzting toell oøer 200 men,
utom.en, and thilàrot itt tlte þur-zipcode area of taest FoñWorth that the ?antr), scrzts.
,A.bout 2,000 pounds
offood ale pur-chased each nrnth.Selections are made
from a shopping listprovided by the Tar-rant Area Food
Bags of stElc grocerl itenzs statzd
rcaþ as Eloise Paula chats ,tDith
one of the cùurdt's Tuesday aisi-
Bank. Name-brand tors. Behind her, Donna lúhitson. Ãeeps USD,!-rcguitdrccords.
rtems are purchased
at bargain prices, and the selections are stored on
shelves and in refrigerators till dist¡ibution day. Fr.
Jon Jenkins, rector of Ch¡ist the King, says the
whole program cost only about $2,500 in 2008.
An air of calm pervades the workroom, and the
team takes an inte¡est in each family it serves. Aretired couple may be offe red some coffee cream-
er; a young mother may come away with a trcat
for her childrent school lunch bags.
"I never knew you were herg" says one fìrst-time
visitor whose husband had his hours cut back at
A223
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 39 of 75 PageID 1157
þ\"ont t/te lli.rlto¡t
ffiwå's WËæ#,tË
suLYwwÉ seby thc Rt. Rea. Jacle L. Iker, Bishop of Fort Worth
Hala you ever stopped to think what a huge sur-
prise that first Easte¡ Day was to the friends of
Jesus? The women going to the tornb early that
morning certainly didnl expect to fìnd it empty!
They had gone to anoint a dead body, not to wit-ness a rcsurrection. Thryhad not exPected to see
the stone rolled avya), and the body ofJesus rniss-
ing frorn his grave.'lhe Gospel writ-ers desc¡ibe them as astonished and
amazed. At first they fai.led to un-
de¡stand what had happened, think-
ing perhaps that someone had come
during the night and stolen the cru-
cified body ofJesus.
And as for his other disciples - Pe-
ter, James, John and the others -where were they? They had not hur-
ried out to the tomb that Easter
morning expecting to see that Jesus
had risen from the dead. No, they
u¡ercstill in hiding, pàralyzeòby
grief and fear, behind the loclced
doors in an upstairs ¡oom ofa friend's house.
When the women came and told them that the
body of Jesus was not in his tomb, thry didnt sa¡
"Oh, yes, we thought this might happen, We ex-
pected Jesus might rise from the dead." No, thryu'ere surprised and bewildered, just like the
women, and they could hardl¡' believe it. So Peter
and John jumped up and ran to the tomb, finding
it just as the women had said. It was only later,
when the risen Jesus came seeking them back in
the upper roorn, thât they understood and be-
lieved.
Easter was Godt great surprise to those first
Christians, and it ¡emains the miraculous act ofGod that is the su¡e foundation of ou¡ faith. B e-
cause Jesus is truly risen from the dead, we know
that we too are raised with him to
eternal Jife, by his grace and power'
Is there room in your faith for God
to surprise you? Is there room fo¡ a
God who raises the dead and heals
the sick and answers prayerl Our
problem is not that we expect too
much of God, but that we expect
too little. But the message of Easter
is that our God does miraculous
things and brings new life in ways
that we do not expect. He is the
God who liberates and delivers us
f¡an sin and death and gives us
hope for the future. All is not lost, even when
things may look rather dismal and bleak. Lo ok to
God through the lens of the Easter faith and ex-
pect him to surprise you in wa1's you may not ex-
pect.
Invite the light ofthe risen Jesus to dispel your
worries,.fears and resentments, that you may know
the jo1' and triumph of ¡esurrection life even now.
4*y,l4M-(J
A224
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(695) 'o¡¡ uu:e¿s.exa¿'g¡Jo¡6 rro¿
CIVda8urso¿'g¡
'3:g r¡+orduo¡¡
T-}IOCESAI.I CALE]\ DAR - EASTËR 2Û09
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Boldface jfe indicates Bìshop Ikcr! aisita¡ions . [Jnlles otberuise indicatcd, all meetings are bcld at tòe Dioccsat Centa'for Ministty
M,t1'
4/73
4/19
4/20
4/26
5/¿
5/3
5/70
5/76
5/17
5/18
5/21
5/24
5/31
Diocesan Offìces closed
Discretion
9:30 a.m. Commission on Ministq,1:30 p.m. Standing Committee
ST. SIMON'S, FortWorth
Diocesan Convocation for all convention delegates,
STJOHN'S, FortWorth
IGLESIA SAN MIGUEL, FortWorth
ECW Qriet Da¡ St.John's, FortWorth
GOOD SHEPHERD, Granbury
9:30 a.m, Committee on Ministr¡,1:30 p.m, Standing Committee
Ascension Day
GOOD SHEPHERD, Brownwood (Bishop lker), and
ST. ANTHONY, Alvarado (Bishop Wandand)
The Da! of Pentecost
ST. LAURENCE, Grapevine
j;'crl\,,!ï!L!.j),li.t.tir¡¡, ¿ f'r.ri:lii:¡t:iixroftirs.lJì<¡<r:se,;rfFt'¡r\tottll, i.s <!i¡tri!:lrtcil six titrr(:s ? ì'{ìi)í
The Rt. Reu Jack L. Iker, publishe4 Suzanne GüI, editor (sgill@fuepiscopal.org)
Offces tl nailThe Episcopal Diocese of Fort V/orth, 2900 Alemeda Street, Fort Worth, Tsas 76108
Telefhone 877 .244.2885 fax 877 .244.3363 wwwfirepiscopal.org
A225
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 41 of 75 PageID 1159
F# {,r¿Mf S5f#ru
King of Glory, Wæo, is meeting in thc cbapel ofthe First Baptist Church. Youngfamilies nøke up
thc majority of the cong'egation.
Át King of Gtory, is vicaS thei¡ Web site is www.ctrfi,v.org.acolyta Will Stamey
and Will Wallace -
On Jan. 23, the Bishop and Canona-slste/ c11on Charles Hough joined Fr. Darryl PigeonHoush uith the':-*6,,:*'' "- and Fr. Randall Foster in Waco for a well-Itos?el leSson.
attended Saturd ay aftern o on service ofconfirmation, The congregatior, which has taken
the name King of Glory was organized b)' friends
Jeff Wallace and Jeff Fish, who paid a visit toBishop Iker in Novem-
ber to ask for adrnission
as a mission station ôfthe diocese. (See theirWeb site at kingofglo-r¡org) Visitors at the
January ccnfirmation
service were greeted by a
young lady of elemen-
tary-sibool age who of-
fe red service bulletins
and asked,'Are you
.¡f É¡r$Íer*doÍ fr{ r.f}r E!,'í'! t'r!le,{ Eiøsa e 4l Ji'ør,r'PFbi'tS'
'74re you coTn;ng to out" church?"
Î{ew ctngregationsactive in worship, ministryWith six new cmgregations added to the diocese
in the closing weeks of2009, Bishop Iker has be-
gun making his first episcopal visitation to each.
During Advent the Bishop visited the diocesan
churdr plant of Christ the Redeemer in Fort
Worth, confirming or receiving 13 members.
Some of those joining the mission churdr,
which meets at the Lockheed MartinRecreati on Area, have transferred from
other área churcÀes; others are new to the
Anglican tradition. Christ the Redeemer
began weekly services just six months ago,
in August 2009 , and is averaging one bap-
tism a monthl Fr. Christophr Culpepper
Lent 20L0
fi: ChristopherCut?eq?er (front roar, right) and Bishop làerposed uith church ntembers qsho tttere confrned orreceiøed øt
Cl¡rist the Redeemer in December.
coming to our church?"
The ccngregationof St. Gabriel's in Springdale'
Ark., hosted an ecumenical Evening Prayer service
on Frid ay Feb. 5. The community event was held
to raise funds for the relief of earthquake victims;
its theme was "Haræ a Heart for
Haiti." Fr. John Slavin represented
the Anglican tradition, while
priests from the local Roman
Catholic and ,trtiochian Ortho-
dox chu¡ctres joined him as wor-
ship leaders, bringing together the
three great strains of Christianity. Reporting on
the sen'ice, the local net/vsPaper called them
'tousins" who "came together for a common
cause." (As it happened, all three priests were
named Johnl) The funds raised during the erening
benefited the Anglican Relief and Development
Fund. To see photos, go to Fr. Slavin's blog,
anglicanapologist,blogspot. ccrn.
A226
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 42 of 75 PageID 1160
affid foa'ginæÍr e$sby the Rt. Reu. Jack L. IÃ.et; Bishop of Fort Wortlt
.Fì'om the lJi.rhop
A seastffi. t f repenta.ffice
-Í-å^.{dM^
The Pharisee stood and prayd thus r.tith hímself "God, I thanh thee that I am not IiA.e
other nten, extot'tioners, utjust, adultaei's, or e'uen liþ.e this tax collector. Ifast t'uice a
,uteek, I giøe tìthes of all that l g:t." But the tax collector, s tandingfar ofi, uould not
eaen lift up his eys to hea'¿pn, but beat his keast, salting, "God lte tnercful to ftre'a
sinner!' ( l.uke 18:1 1-13)
Lent is a penitential season of fasting,prayer and self-denial. Our emphasis for these 40 days is upon
repentance and forgiieness. We are called to recognize and confess our sins, to ask God's forgiveness and
meriry, and to prary for grace to amend our lives according to His will. It means being changed by a daily
pattern of repentance, forgiveness and amendment of life'
In our Lord's parable of the Pharisee and the tax collector (Luke 18:9-14) Jesus contrasts rwo very
differert spiritual anitudes in our relatiorship with God. The first is one of pride, self-righteousness, and
superioriqr The Pharisee reminds God that he is a good and pious man, better than othe¡s. The tax
collector, on the other hand, knovvs he is a sinful man, undesen'ing of God's forgiveness and lot'e. In
sadness and humilit¡ he throws himseJf upon the mercy of the Lod. Jesus concludes with a central
teaching thar runs throughout the entire Bible: "Everyone who exalts himself will be humbled, but he
who humbles himself wil.l be exalted." (verse 14)
Lent is a time to grow in humility' First, it requirs dail¡' ss1¡-txtmination and ccnfession' as we
acknorvledge our faults and failures before God. Second, it requirts contrition, an expressionof our
so¡¡ovfor the things.we have done and left undone. Then we resolve to do better, as we ask for God's
strorgth and help to amend our Jives, and we offer ourselves as channels of His love and forgiveness in
our interactions with others.
Several times a day throughout this Lent, malce a habít of repeating an ancient prayer thât comes to us
f rom the Easte¡n Orthodox tradition called the Jesus Prayer:
Lord Jesus Christ, Son of the liúng God, haac merq) u|oll me a sinner' Lord Jesus
Chrìst, Son of the liøing God, haøe me1'cJt u?on ma ø sinner. LordJesus Christ '-'
2 F^-¡,¡ael r- A/f;,,;",. - f a-t )n1n
A227
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DIOCESAN CALENDAR - LENT 2O1O
l'¡l'll'rlrlnrll"l'1"'lll"'ll"t'l'l'tlt¡lll'r"¡ll¡lilrll
f¿I 1-ç819¿ XI 'tluo/v\ ]'rod
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I\OISSIW"!CldVMìOJ
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March
Áprì/
HOLYTRINITY, Eastland, and ST. ANDREW'S, Breckenridge
GOOD SHEPHERD, Wichita Falls
9:30 a.m. Commission on Ministry1:30 p.m. Standing Committee
1L:30 a.m. Finance Committee
L:30 p.m. Executive Council
Sunday ofthe Passion - Palm Sunday
L0:30 a.m, Mass of Collegiality, St. Vincenti Cathedral, Bedford
Good Friday
Diocesan Offices dosed utztil Tuesday, /{Pril 6
Easter Sunday
AIL SAINTS', FortWorth
3/25
ár:,ffi2s
3/30
4/2
3/1"4
3/21.
3/22
4/4
4/1,1,
Foruard In Mission, a publication of the Diocese of Fort Worth, is distributed six times a year
The Rt. Rev. Jack L. Iker, publisher; Suzanne Gill, editor (sgill@ñvepiscopal'org)
Off.ces tl maìlThe Episcopal Diocese of Fort Worth, 2900 ,Aiemeda Street, Fort Worth, Texas 76108
Telephone 81.7 .244.2885 fax 817 .244.3363 www-fuepiscopal.org
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TAB 8
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 45 of 75 PageID 1163
Journal
of the
Twenty- Seventh Annual Convention
of the
Episcopal Diocese of Fort Worth
l.{ovember 13 - 14,2009
8{,
Special Meeting of Convention
February I ,2009
EXHIBITb
tts tl
A229
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 46 of 75 PageID 1164
Minutes
Before the business meeting, the convention offered the Hoiy Bucharist at All Saints'
Chur.ch on which occasion the Presiding Bishop, the Most Rev. Katharine Jefferts-Schori
was principal ceiebrant and preacher.
The Pr.esiding Bishop called the special meeting to order at I:40 P,M. and, after leading
pra)/er, reulinded the convention that when in a diocese thele is neither sitting bishop nol
itaoding committee, as was the situation that day, the canons of the Episcopal Church
r.equir.e the presidingbishop to consultwith mernbers of the diocese to provide episcopal
ministry and to elect qualif,red pet'sons to other required canonical functions.
The Presiding Bisirop appointed the following acting officers:o Secretary of the Convention The Rev. Bruce W. Coggin
n chair, credentials committee The Rev. Courtland M. Moore
" Chair-, Dispatch of Business Comrnittee Walt Cabe
o Parliamentarian Betty Green
o Cirancellor Kathleen Wells. Chai¡, Elections Committee The Rev. Bill Taylor
Walt Cabe, Chair of Dispatch of Business, presented the agenda (in the hands of all
delegates) and moved its adoption, the motion seconded by many, Motion carried
unanirnously.
The Rev. J. Fl'ederick Barber, Rector of Trinity Church, welcomed the convention on
behalf of the parish vestry.
Mr. Cabe introduced and welcomed the following visitors:o Tire Most Rev. Katharine Jefferts-Schori, Presiding Bishop, the Episcopal Cirurch
' The Rt. Rev. Edwin Guiick, Bishop of Kentucky, and l\4rs. Gulick. The Rt. Rev. Larry Benefield, Bishop of Arkansas. The Rt. Rev. Sam Hulsey, Bishop of Northwest Texas, retd., and Mrs. Hulseyo The Rt. Rev. Rayford High, Bishop Suffragan of Texas, and Mrs' High. The Rt. Rev. Paul Lambert, Bishop Suffragan of Dallas
o Dr. Dean E.'Williams, President, Brite Divinity SchoolI Max Patterson, President, Province VII, the Episcopal Church, and Mrs. Patterson
. The Rev. Canon Rick Cluett, Presiding Bishop's Pastoral Assistant for
Reorganizing Dioceses
" The Rev, Bob Allen, Presiding Bishop's Pastoral Liaison for the Steering
Cornrnittee North Texas Episcopaiiansr The Rev. Michael McErn,en, Province VIi Miiitary Network, and Mrs. McEwen
c The Rev. Tim Carson, Pastor, Univelsity Christian Chulcir (Forl Worth). The Rev. David Lowe. Ann Rudig, Director of Communications, the Episcopai Church
Mr. Cabe further thanked the members of the team that has worked with the Presiding
Bishop to respond to the situation in the Diocese of Fort Worth: Bishop Gulick, Bishop
t9
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Clay Matthews, Canon Cluett, the Rev. Robert Alien, David Beers, Mary Kostel. He also
thanked T¡inity Church, its rector, wardens, and vestry, for the parish's hospiiality during
the months leading up to tire convention.
The Presiding Bishop noted that the ruìes of order and other standing rLtles for the
convention were posted on the diocesan website and proposed their adoption without
reading. A motion to adopt, made and seconded fi'oni the floor, carried unanimously.
As its chair, Fr. Moole gave the Cl'edentials Comtnittee's first report. Of twenty-tluee
(23) diocesan clergy qualified to vote, nineteen (i9) were present. Of the fifty-ftve (55)
congregations in the diocese, thirty-one (31) had either a delegation or a delegate present
with a total of sixty-two (62) voting delegates on the floor. Thercfore a quorum was
present.
Present ResultOrder PossibleOUORUM55 conqresations 31 with 62 delesatesLayOUORUMloClerical 23 diocesan ciergy with vote
The Presiding Bishop invited a motion to give voice but not vote to the Rev. John Keene,
the Rev. James Horton, and the Rev. Maureen Lewis. TIle motion made and seconded
fi'om the floor carried unanimously'
The chair recognized Fr. Moole who nominated the Rt. Rev. Edwin Gulick, Bisliop ofKentucky, to be Provisional Bishop of the Diocese of Fort Worth. Numelous seconds
came from the floor. The Presiding Bishop asked for futfher nominations but hearing
none asked for a motion to close nominations. Tlie motion made and seconded from the
flool carried unanimously.
The Presiding Bishop spoke of her gratitude to Bishop Gutick and the Diocese ofKentucky for acceding to her lequest for assistance'
Fr. Taylor explained that the vote on the nomination of Bishop Gulick wouid be a voice
vote by orde¡s. He called for the clergy vote, which was unanimously in f'avor, He
called for the lay vote which was unanimously in favor except for one abstention. The
Presiding Bishop noted that the "all but universal consent" by voice vote far exceeded the
canonical requirernent of two-thirds consent in both orders and declared the election done
and Bishop Gulick elected.
The convention's work then stopped momentarily wirile the Presiding Bishop installed
Bisliop Gulick as Provisional Bishop of tire Episcopal Diocese of Fort Wotth.
Bishop Gulick spoke of his gratitude to Bishop Katharine and to the convention and
standing committee of the Diocese of Kentucky. He thanked especiaily Mrs. Gulick for'
her patience and corunitment to this enterprise'
Bishop Gulick assurned the chair of the convention and made the followingappointments.
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After Fr. McClain addressed tire convention, the motion carried unanimously.
Walt Cabe, St. Alban's, Arlington, asked Diane Snow, St. Stephen's, Hurst, to make a
special presentation. She in tum presented to the Plesiding Bishop a card with "a¡epresentative sampling" of signatures and expressions of gratitude, oligiral works of art
by Fort Wor-th altist Shawn Reese, and a poen by Deborah Hudson, who read the wot'k.
Fr. Taylor plesented the first report of the election committee. For Trustees of the
Corporation of the Diocese, tlie following were elected and immediately appointed by
Bishop Gulick:
" Robelt M. Basso The Rev. James Hazel. Cherie Shippo The Rev- Jolm Stanley
" Trace Wonell
The following pei'sons were also eiected to the off,rces indicated:. Standing Committee, lay ot'der
. Anne T. Bass
. Walt Cabe
¡ Standing Cornmittee, clerical order. The Rev, Fred Barber. The Rev. Chris Jamborn The Rev. David Madison
o Deputies to General Convention 2009, lay ordero Margaret Mieuli. Katie Shenod
. Deputies to General Convention 2009, clerical ordel. The Rev. Fred Barber
' The Rev. Chris Jambor. The Rev. Cqurtland Moore
In the election for standing committee, lay order, George Komechak withdrew. ln the
election for Deputy to General Convention 2009, the Rev. Sharla Marks withdrew.
AÍter delegates marked ballots, Bishop Gulick called for courtesy lesolutions.
Fr. Tayior presented and moved the adoption of a number of cour-tesy resolutions
addressed to:. Ft'. Moore. Wait Cabe. Bishop Hulsey. The Presiding Bishop. Bishop Gulick and the Diocese of l(entuckyc Episcopalians across the church who have prayed for our diocese
" Trinily Church, FW
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. All Saints Ciiurch, FW
. St, Christopher Church, FWc Various diocesan groups that supported the effort to reorganize
. The convention planning committee
All courtesy resolutions were moved by Fr. Taylor, seconded from the floor, and passed
unanimously.(The text of all courtesy lesolutions is in tire Appendix.)
Fr-. Sta¡ford rose to thank Mrs. Gulick for "lending" her husband to the Diocese of Fort
Worth. The bisliop asked his wife to stand in tesponse to enthttsiastic applause.
Fr. Pool suggested sending greetings in writing to the former bishops of tire diocese,
which actíoir Bishop Gulick assured rvould be undeftaken.
Fr. Taylor plesented the second report of the elections committee. The following persons
were elected to the office indicated.. Deputy to General Convention, lay order: Kathieen Wellso Tnrstee of the University of the South, lay order: Shelri Glaset'
In the election for Standing Committee, iay order, Prescott and Sheuod wilhdrew. ln the
election for Deputy to General Convention 2009,\ay order, Fagley, Guinn, and Walker
withdrew. In the election for Deputy to General Convention 2009, Coggin, Reeves,
Reynolds, and Slaughter withdrew.
There being only a single candidate left for Standing Committee, lay order, Fr'. Barber'
moved the election of Margaret Mieuli by acclamation. After second from the floor and
clarification by the chancelior and parliamentarian, Bishop Gulick asked for the vote,
Margaret Mieuli was elected unanimously.
After delegates marked bailots, Fr. Moore read a letter to the convention from Bonnie
Anderson, President of the House of Deputies of the General Convention of the Episcopal
Church, in wliich she assured the diocese of her prayers and support and weicomed the
diocesan depr"rtation to General Convention 2009'
Afrer consultation with the chancellor and others, Bishop Gulick directed the elections
committee to study the voting history in the elections for both lay and clerical deputies to
General Convention 2009 and nominate an alternate or altemates in both order-s, after
which he would ask for a voice vote by orders to approve those nominations. To this
direction the convention acceded.
Bishop Gulick announced that the annual diocesan convention will meet November 13
and L4, the location not yet settled.
Bisliop Gutick recessed the convention for five minutes
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Upon resumption of business, Fr. Taylor presented the third repoit of the elections
committee. The following person was elected to the office indicated.o Deputy to General Convention 2009, clerical order: The Rev. David
Madison
ln the election for Deputy to General Convention 2009,\ay order, Killingswoúh, Minor,
and Prescotl withdrew
Fr. Moore pointed out that since only fifty-two (52) lay ballots were cast, Susan Reeves
was in fact elected, tirus completing the election of lay deputies to General Convention
2009. Therefore:. Deputy to General Convention2)}9,lay order: Susan Reeves
Fr. Madison moved that Victolia Prescott be elected alternate lay deputy to Genelal
Convention 2009. Upon second fi'om the floor, Bishop Gulick called for a voice vote by
olders, both of which approved unanimously. Tlierefore:r Alternate Deputy to Generai Convention 2009,Lay order: Victoria Prescott
Fr. Madison rnoved that Fr. Coggin and Deacon Nocher be elected alternate clerical
deputy to Genelal Convention 2009. Upon second from the floor, Bishop Guiíck called
foi a voice vote by ordels, both of which approved unanimously. Thelefore:n Alternate Deputy to Genelal Convention 2009, clerical ordet': The Rev.
Bluce W. Coggin, The Rev. Janet Nocher
All elections completed, Bishop Gulìck adjourned the conventi on sine di.e at 5:30 y.tvt.
Respectfr"rlly submitted,The Rev. Bruce W. Coggin, Seoretary
Convention of the Diocese of Fort Worth
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Linder Seeber', St. Martin, KellerSuzaure Russell, AII Saints, Wichita FallsUTOBetty Jo Everett, St. All¡an, ArlingtonMarli Fagley, Parker CountY
Sherly Hunt, Triníty, F\ilMeredith Killingsrvorth, St. Alban, Arlington
Episcopal Church W'ornen
ElectedOfficeBassCabeMieuli
Standing Cotruaittee, laY tnernber
BarberJamborMadison
Standing Cotnmittee, clerical tnelnber
Sher¡odMieuliReevesWells
GC Deputy, lay order
BarberJzunborMadisonMoore
GC Deputy, clerical order
PrescottGC Alternate orderCogginNocher
GD Alternate DeputY, clerical order
GotcherGlaser
Trustee, University of the South
Elections
Election Tallies: Boldface indicates election.
Trustee, Corporation of the Diocese
Baliot J2LayLav Cle¡gyLav ClergyClersv
I8 52l8 626¿r827'r.., 1032 1010Needed to elect
58t'lR. Bass487'1J. Hazcl
03 74R. Hicks2506P Jefferson
04 t0D. Kentll06J, Nanna
10C. Shipp 43
3912J. Stanley01 00K. Welis10T,Worrcll
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The chair recognized Deacon Shalla Marks to speak for the community of deacons within
the diocese. sttr noted that two deacons-the Rev. Susan Slaughter and the Rev.
a"r6^Gitane would soon be priested, leaving four deacons working in the diocese'
o The Rev. Janet Nochern The Rev. Sharla Marks. The Rev. Linda Sutheriand. The Rev. Dana Wilson
Deacon Mar.ks asked the Convention to foliow the deacons' lead in 2010by connecting
with schools public and private whose students come from low income families and
offered assistance in contatting and dealing with school stt'uctttres and setting up working
relationships.
The chair recognized Jane McClain (St. Luke, Stephenville) wlto spoke of the Finance
Comrnittee,, plun, to offer leadelsliip training tools for tr-easllrers and other parish
leaders, especially those without previous expelience'
. A checklist for h.easurers to assure compliance witli both civil and ecclesiastical
bookkeeping and repoÚing requirements
n A leadership tr-aining workshop scheduled for February 20,2010, at All Saints
Church, Fort Wortli ied by Mr. Bob Schor of the Diocese of Texas who
regularly trains lay leadership in that diocese
r A nuts-and-bolts training session for treasurers in the late spring, 20i0
The ohair recognized Fr. Barber to read a letter from the Presiding Bishop (see
Àppendix). Fr.-Bar-ber then moved "that this Convention of the Episcopal Dioces^e of
Fort Worth accede to your wishes and the resolution of the standing committee of the
episcopat Diocese of Iientucky to release you fr'om the obligations you assumed on our
bêhamwhen you were elected irovisional bishop at the special convention on February 7,
2009.- Upon second flom the floor and ttie vote, the motion carried unanimously'
on behalf the standing committee, Fr. Barber then nominated the Rt. Rev. C' Wallis
ohl, retired Bishop of ãhe Diocese of Northwest Texas, as the next provisional bishop of
the Diocese of Fort Worth, to be effective upon his installation at tire end of the
Convention today. Seconds came fi'om the floor. Bishop Gulick called for fuÉher
nominations, and hearing none declaÏed norninatious closed.
Fr. Bar.ber reported that the Standing Committee, in consultation with the Presiding
nirnnp as requir.ed by Episcopal church canon IIL13.1, recommends the election of
Bisirop Ohl as our next provisional bishop.
After cornmenting on Bishop ohl's fitness for the office, Bishop Gulick called for the
vote by orders, ãnd Bishop ohl was elected unanimously. Immediately upon the
eiection, the convention paused while Bishop Gulick led the liturgy to install Bishop Ohl
as Provisional Bishop of the Episcopal Diocese of Fott worth.
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You are all awesome icons of an awesome God "wl')ose power working in us can
do infinitely more than we can either ask or imagine. Glory to Him from generatiou togeneration in the church and in Christ Jesus. Amen.
II.Summary of Actions
Bishop's Nominations, Table I
ElectedOfficeRobert Bass, term ends 20 I 3
The Rev. James Hazel, term ends 2012Cherie Shipp, terrn ends 201 IThe Rev. John Stanley, ten¡ ends 2010Trace Worrell, term ends 2014
Trustee, Corporation of the Diocese
The Rev. Bruce W. CoggrnSecretary of ConvetitionPlatt Allen, Trinity, FWTreasurerKathleen Wells, Trinity, FXChancellorLinda Johnson, St. Anne, FWRegistrarDavid Leedy, All Saints', FWHistoriographerThe Rev. J. Frederick BarberEcumenical OfficerAnne Bass, Tlinity, FWTad Bit'd, ASESThe Rev. James HazelRobert Hicks, St. Christopher, FWFloyd McKneely, St. Stephen, HurstShannon Shipp, Trinity, FWDavid Skelton, St. Mary, HillsboroWhit Smith, All Saints, FW
Trustees, Fund for tlie Endowment of theEpiscopate
Lynne Allen, Trinity, FWTad Bird, ASESThe Rev. Mel Bridge, ASESThe Rev. David Madison, ASESJeanie Pitre, ASESKaren Shepherd, Trinity, FWThe Rev. Bill Stanford, St. Christopher
FV/Catherine Stehlilc, St. Martin, KellerTrace Worrell, All Saints, FWLee Ann Wyss, St.
Commission on Episcopal Schools
The Rev. Frank Reeves,Janice Schattman. CTK, FW
Ecclesiastical Trial Court
The Rev. Melanie Barbarito, All Saints,FW
Victoria Prescott, ECPCJoel Walker, St. Martin, KcllcrThe Rev. Dana rùy'ilson
Comrnission on Ministry
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Fr. Bill Stanford, St. Christopher, FW
Fr. John Stanley, ret'd.Fr. Bill Taylor, Trinity, FWAnn Tuclcer, St. Martin, KellerKathleen Wells, TrinitY, FWFr. David Madison, All Saints School, ChairLaura Adcock, All Saints, FWJoe Christopher, St. Luke, Stephenville
Sandra Liser, Trinity, FWJane McClain, St. Luke, Stephenville
Fr. Bill Taylor, Trin iry, Fw
Resolutions Committee
Dcn. Janet Nocher', TrinitY, FWRelief and DevelLynne Minor, All Saints, FWto Province VIIDonna Clopton, Christ the King, FWMarti Fagley, Parker CountY
Dorothy Hood, St. StePhen, HurstBetty Torlence, St. Stephen, Hurst
Daughters of the King
Frances, Cox, Trinity, FS/Lynne Stanley, Trinity, F W
Jean Wilson. Trinitv, FW
Wolrell's Cabinet
Dolly Bush, Trinity, FWMarian Cole, St. Luke, StePhenville
Laurie Cruse, All Saints, Wichita FallsMarti Fagley, Parker CounfY
Diane Jackson
Carla Kerr, Parker CountYSusan Lowder, St. Stephen, HurstMarion McAlister, Trinity, FWLinder Seeber, St, er
Diocesan Altar Guild
Suzanne Russell, All Saints, Wichita FallsUTOBetty Jo Everett, St. Alban, ArlingtonMarti Fagley, Parker CountY
Sherry Hunt, Tl'inity, FWMeredith Killinssworth, St, Alban, Arlington
EpiscopalChurch Women
Elections
Bishop Ohl was elected unanimously on a vote by orders. Since other candidates were
unoppìsed, the eier,tions of clerical member, Standing Committee; lay member,
Ecclésiastical Court; clergy member; and Trustee, University of the South were all by
acclamation.
ElectedOfficeThe Rt. Rev. C. Wallis OhlProvisional Bishop of Fort WoÉh
F\/Mieuli sr.Standine Committee, Iay memberThe Rev, David ASESStanding Committee, clergy membet'J an ice FWmemberEcclesiasticalThe Rev. Frank ReevesEcclesiastical
FWGlaser sr,ofthe SouthU
Boldface indicates election.
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In the election of lay tttember, Standing Committee
Ballot 1
LayClergy22 50Voting
2611Needed to elect
12 35M. Mieuli1510J. L. Nanna
Motions Made, Seconded, and Canied
Second PurposeNo. Movel'Gotcher Refer bishop's letter to Standing Çp4glttge1 Smith
Suspend ruleStanford Weidler2Give licensed clergy seat and vote3 Floor Floor
Floor Adopt a-qenda4 Caberules ofMadison Floor5
Waive reading of rules6 Madisolr FloorPool Give Bp Ohl seat and voiceBarber
Give youth representatives seat and voiceFloor Flooro
Pool Seat anv delegation despite certain anomalies9 MooreFloor Confi rm bishop's nominees10 Reynolds
Elect candidates acclamationFloor11 TaylorFeb '09 Resolutioin 1Madison Pool12
Crews Ratifu certain actions of Feb '0913 MadisonCox Anent church properly14 Madison
Amend Resolution 4Gotcher' McKneely15Amend Resolution 416 Pool Meeks
Floor Provide for provisionaì bishop17 MadisonI(elly Promote transparent decis ion makin.q18 Madison
Create diocesan strûcture commissionMadison Lefler19Coordinate key ministries20 Madison Pool
Floor Certain parishes changed to missio NS21 BarberAdopt temporary budqetFloor22 McKneelyGive full to church-wide23 McClain PoolAdopt constituti onal changes24 Madison Bass
Smith canonical25 MadisonRelease GulickBarber Floor26Nominate Bp. OhlBarber Floor27
Floor Courtesy resolution Owanah AndersonaoLO TavlorFloor resolution: B Gulick29 Taylot'
l'esolution: Mrs. GulickFloor30 Taylorresolution: Diocese of KenTavlor Floor31
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Standing Committee
Officers elected:o President: The Rev. Fred Barber
o Secretary: Margaret Mieuli
Bishop' s appointtnents confitmed:. Chancellor: Kathleen Wells. Tleasurer: Platt Allen. Secretal'y: The Rev. Bluce Coggitt
. Registrar: Linda Johnson
Requests fol consent:, Consent granted for election of Scott Mayel as Bishop of Northwest Texas
. Colsent witirjreld for election of Kevin Thew Forrester as Bishop of Northem
Micliígan. Consent given for lequest of Diocese of Springfield to elect a coadjutor bishop
Othei'actionsSent letter to former Bishop lker, through his attorney, requesting an orderly
transition of records and properties.
Heard report on cofilmunication stlategy.
Approved Standing Committee retreat.
Apþroved actions taken by Bishop Gulick to protect legal interests and upliold the
Cäãstitution and Canons of the Episcopal Diocese of Fo't Worth.
Requested Standing committee of Diocese of Kentucky to agt'ee to extend Bishop
Guùck's time as plovisional bishop of Fort Worth.
concuned with discipiinary notíces to all fotrneÎ diocesan clergy.
Deputized The Rev. David Madison to recruit a committee to implernent
Reiolution 4 fi'orn February 7,2009 special convention'
Named Resolution 4 Committee: chair Jeny Nanna, The Rev. Bruce coggin,
iurun Hekman, Marti Fagley, Leslie Guinn, Wliit Srnith; liaison, The Rev. David
Madison.concuüed with bishop's letters of inhibition to all diocesan clergy who
abandoned the Episcopal Church
Determined election pfocess for fiiling vacancies on the Standing Colnmittee'
Approved ordination of Deacon Susan Slaughter to the priesthood.
Approved nornination of Bishop wallis ohl as next provisional bishop.
a
a
a
a
a
o
a
a
a
a
a
Loan considet'ed:. St. Christopher's, Fol't Worth: $200,000 tnort¿age witir 15 year nraturity:
approved
Disciplinary actions: See Bisltop Guliclc's Official Acts fot detaiis'
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EXHIBIT G
Case 4:10-cv-00700-Y Document 30-4 Filed 12/13/10 Page 58 of 75 PageID 1176
CAUSE NO. 141-237 r0s-09
THE EPISCOPAL CHURCH, THE RT.REV. C. WALLIS OHL, ROBERT HICKSFLOI'D MCKNEELY, SIIANNON SHIPP,DAVID SKELTON, and WHIT SMITH
Plaintifß
FRANKT,IN SALAZAR, JO ANN PATTON,V/ALTER VIRDEN, III, ROD BARBER, C}IADBATES, TTIE RT. REV. JACK LEO IKER, JTIDYMAYO, JULIA SMEAD, THE REV. CHRISTOPHERCANTRELL, TIIE REV. TMOTHY PERKINS, andTIIE REV. RYAN REED
D efend ants/C ounter-D efend ants
THE ANGLICAN PROVINCE OF THE SOUTI{ERNCONE'S "DIOCESE OF FORT'WORTH"
Defendant/Third-Party Plaintiffl Counter-Defendant
THE ANGLICAN PROVINCE OF THE SOUTIMRNCONE'S "CORPORATION OF THE EPISCOPALDIOCESE OF FORT V/ORTH''
Intervenor/Third-P arty Pl ainti fflD efendanVCounter-D efendant
ST. ANTHONY OF PADUA CHLIRCH (Alvarado),ST. ALBAN'S CHURCH (Arlington), ST.MARK'SCHURCH (Arlington), CHURCH OF ST. PETER andST. PATIL (Arlington), CHIIRCH OF ST. PHILIPTHE APOSTLE (Arlington), ST. VINCENT'SCATHEDRAL @edford), ST. PATRICK'S CHURCH(Bowie), ST. ANDR-EW' S CHURCH (Breckenridge),
GOOD SHEPHERD CHURCH (Brownwood), ST.JOHN'S CHURCH (Brownwood), CHURCH OF ST.JOHN THE DTVINE (Burkbumett), HOLYCOMFORTER CHURCH (Clebume), ST.MATTIIEW'S CHURCH (Comanche), TRINITYCHURCH @ublin), HOLY TRINITY CHTIRCH
@astland), CHRIST THE KING CHTIRCH (FortV/orth), HOLY APOSTLES CHIJRCH (Fort Worth),IGLESIA SAN JUAN APOSTOL (Fort Worth),
VS.
AT.FIDAVIT OF JONATHAN NNI,SOT'{ PAGE 1
IN THE DISTRICT COI]RT OF
TARRAN'T COLINTY, TEXAS
141ST DISTRTCT COURT
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IGLESIA SAN MIGLIEL (Fort trVorth), ST.ANÐREW'S CHURCH (Fort Worth), ST. ANNE'SCHURCH (Fort Worth), CHTIRCH OF ST.BARNABAS TIIE APOSTLE (Fort Worth), ST.JOHN'S CHIIRCH (Fort V/orth), ST, MiCIIAEL'SCHURCH (Richland Hills), CHURCH OF ST. SIMONOF CYRENE (Fort Worth), ST. TIMOTHY'SCHURCH (Fort Worth), ST. PAUL'S CHUR.CI-I(Gainesville), GOOD SHEPHERD CHURCH(Granbury), CHURCH OF THE HOLY SPIRIT(Graham), ST. ANDREW'S CHIJRCH (GrandPrairie), ST. JOSEPH'S CHLIRCH (Grand Prairie), ST.LAIIRENCE'S CHURCH (Southlake), ST. MARY'SCHURCH (Hamilton),TRINITY CHURCH(Henrietta), ST. MARY'S CHURCH (Hilisboro), ST,ALBAN'S CHLIRCH (Hubbard), ST. STEPHEN'SCHURCH (Hurst), CHIIRCH OF ST. ïHOMAS THEAPOSTLE (Jacksboro), CHURCH OF OIIRLADYOF TIIE LAKE (Laguna Park), ST. GREGORY'SCHURCH ) (Mansfield), ST. LUKE'S CHIIRCH(I\dineral \ilells), CHLJRCH OF ST. PETER BY TIIELAKE (Graford), ALL SAINT'S CHURCH(Weatherfod), ALL SAINT'S CHURCH (WichitaFalls), CHURCH OF THE GOOD SFIEPHERD(V/ichita Falls), CHURCH OF ST. FRANCIS OFASSISI (Willow Park), ând CHURCH OF THEASCENSION & ST. MARK @ridgeport)
Intervenors/Third-Party Plaintifß/D efend ants/Counter-D efen dants
VS.
MARGARET MMULI, ANNE T. BASS, WALTCABE, THE REV. CHRISTOPFIER JAMBOR, TIIEREV. FREDERTCK BARBER, TT{E REV. DAVIDMADISON, ROBERT M. BASS, CIIERE SHIPP,DR. TRACE \¡I/ORRELL, THE REV. JAMESHAZEL, THE REV. JOHN STANLEY, THE RT.REV. EDWIN F. GULICK, JR. and KATHLEENV/ELLS,
Third-Party Defendants/Counterclaimants
T}IE EPISCOPAL CHURCH,
Third-Party Defendant
AFFTDAVIT oF Joxernen Nrmon Pecr2
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AFFIDAVIT OF JONATHAN NELSON IN SUPPORT OF EPISCOPAL PARTIES'MOTIONS FOR SUMMARY JUDGMENT
STATE OF TEXAS
COTINTY OF TARRANT
BEFORE ME THE UNDERSIGNED AUTHORITY, on this day personally appeared
JONATHAN NELSON, who, being by me personally sworn, upon his oath stated:
l. My name is Jonathan Nelson. I am over eighteen years of age, of sound mind, and
fully capable and competent to make this Affidavit. I have personal knowledge of the facts
stated herein, and all facts stated herein are true and correct.
2. I was counsel of record for the Corporation of the Episcopal Diocese of Fort.
Worth (the "Corporation") in its 1994 lawsuit styled Corp. of the Episcopal Diocese of Fort
Worth v. McCauley, Cause No. 153-144833-92 in the 153rd Judicial District Court of Tarrant
County, Texas. As a result of my role as counsel in the case, I have personal knowledge of the
proceedings and outcome of the case.
3. The l9941awsuit resulted in a settlement by which the Corporation recovered the
real and personal property of the Church of the Holy Aposties for that parish, the Corporation,
and the Episcopal Diocese of Fort Worth.
4. Attached hereto as Exhibit 1 is a true and correct certifi.ed copy of Plaintiffs'
Second Amended Original Petition and Application for Temporary Injunction and Permanent
Injunction, filed in Corp. of the Episcopal Diocese of Fort IVorth v. McCauley, as ceftified by the
District Clerk of Tarrant County, Texas.
5. Attached hereto as Exhibit 2 is a true and correct certified copy of Plaintiffs'
Motion for Summary Judgment, filed in Corp. of the Episcopal Diocese of Fort Worth v.
McCauley, including the Affidavit of Bishop Jack Iker and the Affidavit of Reverend Canon
$
$
$
AFFIDAVIT ON JOTT¿,TU¡T'I NELSON PAGE3
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Billie Boyd (dated November i9, i993), as certified by the District Clerk of Tarrant County,
Texas.
6, Attached hereto as Exhibit 3 is a true and correct certified copy of Plaintiffs'
Second Supplemental Evidencç in Support of Their Motion for Summary Judgment, including
the Affidavit of Reverend Canon Billie Boyd (dated Februæy 11,,1994) and the Afñdavit of The
Reverend Canon Charles A. Hough, III, filed in Corp. of the Episcopal Diocese of Fort Worth v-
McCauley, as certified by the District Clerk of Tarrant County, Texas.
7 , Attached hereto as Exhibit 4 is a true and correct certified copy of the Affidavit of
The Rt. Rev. 'William C. Wantland, filed in Corp. of the Episcopal Diocese of Fort W'orth vt.
McCauley,as certified by the District Clerk of Tarrant County, Texas.
8. Attached hereto as Exhibit 5 is a true and correct copy of the certified copy of the
Bnef of Amici Curíae Rt. Rev. Jack Leo lker, Bishop of the Episcopal Diocese of Fort Worth,
and Rt. Rev. Robert Duncan, Bishop of the Episcopal Diocese of Pittsburgh in Support of
Samuel L. Edwards and the Wardens and Vestry of Christ Chrxch, St. John's Parish, Accokeek,
Maryland Supporting a Reversal of the Court's Judgment, filed in Dixonv. Edwards, No.01-
233"1 ln the United States Court of Appeals for the Fourth Circuit, that was certified by the Clerk
of the United States Court of Appeals for the Fourth Circuit and was previously filed in this case
on Septernber 3,2009.
g. Attached hereto as Ëxhibit 6 is a true and correct copy of the certified copy of
Plaintiffs' Original Petition, filed in The Episcopal Diocese of Dallas v. Mattox, No. 84-8573 in
the 95th Judicial District Court of Dallas County, Texas, that was certified by the District Clerk
of Dallas County, Texas and was previously filed in this case on Septemb er 3,2009.
Är¡'ro¿vrr oF JoNATHAN NþLsoN PAGE4
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10. Attached hereto as Exhibit 7 ís a true and correct copy of the certified copy of the
Judgment in The Episcopal Diocese of Dallas v. Mattox,No. 84-8573 in the 95th Judicial District
Court of Dallas Count¡ Texas, that was cerlified by the District Clerk of Dallas County, Texas
and was previously filed in this case on September 3,2Q09.
11. Attached hereto as Exhibit 8 is a true and correct copy of the ccrtificd copy of the
Articles of Incorporation of Corporation of the Episcopal Diocese of Fort Worth, as filed with
the Texas Seoretary of State on Februar y 28, 1983, that was certified by the Oft-rce of the
Secretary of State of Texas and was previously filed in this case on Septemb er 3,2009.
1,2. Attached hereto as Exhibit 9 is a true and corect copy of the certified copy of the
Articles of Amendment to the Articles of Incorporation of Corporation of the Episcopal Diocese
of Fort'Worth, as filed with the Texas Secretary of State on Novemb er 4, 1987, that was ccrtified
by the Office of the Secretary of State of Texas and was previously filed in this case on
September 3,2009,
13. Attached hereto as Exhibit 10 is a true and correct copy of the certified copy of
the Articles of Amendment to the Articles of Incorporation of Corporation of the Ðpiscopal
Diocese of Fort Worth, as {iied with the Texas Secretary of State on November 27, 1997, that
was certified by the Office of the Secretary of State of Texas and was previously filed in this
case on September 3,2009.
74. Attâched hereto as Exhibit 11 is a true and correct copy of the certified copy of
the Amended and Restated Articles of Incorporation of Corporation of the Episcopal Diocese of
Fort .Worfh,
as filed with the Texas Secretary of State on September 5,2006, that was certified
by the Office of the Secretary of State of Texas and was previously filed in this case on
September 3,2û09.
AFFIDAvTT op Jox¿rrnx NELSoN Pacn 5
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15. Attached hereto as Exhibit 12ts a true and correct copy of the certified copy of
the Amended and Restated Articles of Incorporation of Corporation of the Episcopal Diocese of
Fort Worth, as filed with the Texas Secretary of State on April L4,2009, that was certified by the
Office of the Secretary of State of Texas and was previously filed in this case on September 3,
2009.
L6. Attached hereto as Exhibit 13 is a tue and correct copy of the certified copy of
the Certificate of Correction, as filed with the Texas Secretary of State on April 21.,2009, that
was certified by the Office of the Secretary of State of Texas and was previously filed in this
case on September 3,2009
SUBSCRIBED AND SVTORN TO BEFORE ME this day of October,2010.
lic, of Texas
My commission expires:
AFFrD^avIT on Joxersan NELSoNUS 592539v1
KAHEN A.NcÊar!'PuUkt .
ST¡ITE OFTEXTEMy C¡nlm. 00ßù¡2t12
P¿.c¡ 6
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TAB 1
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c.âusE No, t"53-144833-92
CORPORATION OF THE EPISCOPALDfocESE or FORT !ìIORTH,CHURCH OF THE HOLY APOSTLES
IN THE DTSTRICT COURT
VS TARR.A,NT COUNTY, TEXI\S
THE REVERBND M.L. MCCAULEY,SOMETIME RECTOR ÀND CHAÏRMANOF T}IE VESTRY OS' CHURCH OFTHE .HOLY APOSTLES; ALBONHEAÐ, SOMETTME SENTOR T{ÀRDENAND SrEVE BLACKMAN, SOMETTME.,]UNTOR IVARDEN OF CHURCH OFTHË HOLY APOSTLES' HORÀCEBOOTH, HOMER COX, BECKYHEAD, ROBERT MTLLER, ROBERTP.A.LMER, JEAN RTCHARDSON,DON SHÏPE, PAUL SNELL,AND JAI,IES CHARBONNEÎ, SOMET]MEMEMBER OF THE VESTRY OF CHURCHOF THE HOLY APOSTLES' AND THESCHISMÀ,TIC AND PURPORTED CHURCHOF THE HOLY.APOSTLES 153RD JUDTCTAIJ DTSTRICT
PI,ATNTII'FS, SECONÐ ÃIIIENDED ORIGINAT, PETIITON :ANDIPPIJTçÂTIqNFOR TEMPORARY INJUNCTION ÃND PERMANENT':TNTIIJ.NCTTON
TO THE TIONORÃBLE JUDGE OF SATD COURT:
Now coMES the coRPORÀTIoN OF THE EPISCOPÃL DIOCESE oF FORT
WORTH and CTIURCH oF THE HoLY APOSTLES, Plaintiffs, complaining of
The Reverend M. L, Mccauley, Sometime Rector and Chairman of the
Vestry. of Church of the Hoty Äpostles; Albon Head, Sometime Senior
Warden and. Steve Blackman, So¡netime Junior Ï,iarden of Chursh of the
HoIy Apostles; Horace Booth, Homer Cox, Becky Head, Robert Mil1er,
Robert Palmer, Jean Richardson, Don Shipe, Pául Snell, and JameÈ
Charbonnet, Sometime Members of the Vestry of Church of the Holy
Apost1es,' and the Schismatic and rurrpphtf$f UlBlü"h of the HoIy
J
ssss6
ss5
ssss5
sssss
ssss
Apostles, Defendants, and ur gtot,rrd"Ur itå ått"Hgfå show the court
r r;.ì .r afI tljl :o.
i¡iki l:iiiTt
age 1 of 16
ÅlH0LY/1 - 1ÀlPst
þ
4i-ììt If.i -: iÍ5
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the fol-Iowing:
1. pl-aintiff Corporation of the Episcopal- Diocese of ¡'ort
Worth (r'the Diocesan Corporationrr) j-s a not-for-profit corporatÍon
organized and doing business under the Laws of the State of Texas
with its principal office and place of business in Tarrant County,
Texas. It holds lega1 title to propertÍes used for relígious
purposes by parishes, missions and ecclesiastical institutions of
the Episcopal- Diocese of Fort Worth (r'Diocesetf ). In particular, it
holds legal tiÈIe to certain real property used for relj-gious
purposes and beneficíal]y ovned by Church of .the Holy Apostles
lying and situated in Tarrant County, Texas, further described on
Exhibit ilA¡t attached trereto and hereby incorporated by reference
for all purposes (t'the Real Propertytt).' 2. Ptaintiff church of lhe Holy Apostles ("Holy Àpostlesr')
is an unincorporated association organized for relígious purposes
as a parish of the Episcopal Diocese of Fort Vlorth (ttthe Dioceser'),
wíttr its principal office and place of business in Tarrant County,
Texas. Holy Apostles acts through its Rector, InTardens and Vestry.
3. Defendant The Reverend M. L- McCauley, a resídent of
Tarrant County, Texas, IÂIas Rector and Chairman of the Vestry of
Holy Apostles at all tines relevant hereto untíl his inhibition on
Ostober 5, Lggz, âs described hereinbelow. He may be served at
Holy Apostles, 3900 LongTvue Avenue, Fort Worth, Tarrant Countyr
Texas. The Vestry of Holy Apostles have the authority and
responsibility for certain day-to-day conduct of the parísh's
pulur¡frq' rlnsr nmrlDe0 -oB.lqtuRl- pEr¡r¡0ru
renpbnÁnÍ iñiuñcilo¡¡ ¡¡lo pr8¡¡nurxr lN¡ulcrlo¡{ ' Page 2 of 1ó
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business which are granÈed to thern by canon law.
4. Defendant Albon Head, a resident of Tarrant County,
Texasr wâs SenÍor Warden and a member of the Vestry of Holy
Àpostles at all- times relevant hereto until- on or about October 4,
ltgglr âs described hereinbelow. He may be. served at 13,75I Old
Irleatherford Road, Aledo, Parker County, Texas
5. Defendant Steve Blackïnan, a resident of Tarrant County,
Texas¡ wâs Junior Ï{arden and a member of the Vestry of Hol-y
ApÕstles at all times relevant hrereto until on or about October 4,
L992, âs described hereinbelow. He may be served at 2AL2 Adams
Lane South, .A.zl-e, Tarrant County, Texas.
6. The Vestry of Holy Apostles consisted of those named
above and an additional ten members at all times relevant hereto,
until" on or about October 4, 1"992, as described hereinbelow' Nine
of said Vestry members, Defendants herein, are those nor,u listed.
who reside and may be served at the address in Tarrant county
(unless otherwise stated) shown opposite each name:
1. Horace Booth, 106 Circle Dr., Weat'herford, Parker County'
rx 76087
2, Ilomer Cox, 464 MeadowhiJ-I Dr., .Benbrook, TX 76126
. 3. Becky Head, 12 Bounty Rd. w., Fort !üorth, TX 76132
' 4. Robert Mi1ler, 23l-3 Harvest GIen Ct., Ft. ldorth ' TX 76108
5. Robert Palmer, 7 Frank Lane, Granbury, Hood County, TX
7 6049
6. Jean Ríchardson, 728 llinters, For:t l.Iorth, 'IX 76LL4
PLÂINTIFÍS' EISST AI4E!!ED !B]!I¡IAL PETITION ÀND APPLICATION FOR
TEI'IPORARY INJUNCTION AND PERI'IANEUJ INJUNCJISN - Page 3 of 1ó
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7. Don Shipe, 3 Lombardy Terrace, Fort' I'lorÈLr, ÎX 76132
8. Pauf Snell r 2229 Huntington, Fort Worth, TX 761-J-O
9. James Charbonnet, 8034 Meadowbrook Dr-, Fort Worth, TX
7 61-20
7. The Schismatic and Purported Church of the Holy Apostles
ís ân unincorporated association or. not-for-profit corporation
organized for religious purposes as a member of the Antíochean
Orthodox Church. It is composed in pârt of some persons who have
heretofore been parishioners of Episcopal Church of the Holy
Apostles but have become members in the Antj-ochean Orthodox Church
in accord.ance with action of the Sometime Vestry on or about
Octobef 4, :|gg2, as described hereùnbeIow, and subsequent acts
described hereinbelow.
B. The Episcopal Diosese of Fort !üorth is situated in all or'
parts of twenty-four counties in North central Texas, including a1-1
of Tarrant County, Texas. It is a diocese of The Protestant
Episcopal òhurcn in the United States of America ("The Episcopal
Church"), which is a confederation of dioceses situated primaril"y
in the United States, but also in Latin America and'Europe. The
Bishops of The EpÍscopal Church arP members of the Anglican
Communion, which is composed of Bishops of the Church of England
and numêrous other Anglican churches worl-d-wid.e' The .Ang1ican
Communion is itself in communion, reciprocally acknowle<iging
valid.Íty of each others Orders and Sacraments, with certain other
Anglícan churches around the wortd.. The Anglican Communion, the
pLAtNTIfFS' FJRST At4ENpEp oRIGINAL PEIITIoN At{D APPL¡çATlory:FQ8iEflqAB - Pase 4 of 1ó
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Episcopal Church and the Episcopal Dj-ocese of Fort florth are not incommunion with the various orttrodox Churches, including the
Antj.ochean Orthodox Church. Conseguentlyr Do member of the
Antiochean Orthodox Church is in communion with the Episcopal
Bishop of Fort Worth..
g. The EpÍscopal Church, originating in the North Àmerican
colonies as a part of the Church of Engiland, is an historícRefonnation church. It separated from the Roman Catholic Church inthe sixteenth century but preserved cathol"ic faith and order,
including the .Apostolic succession of its Bishops and.-the three-
fold Orders of Bishops, Priests and Deacons. The Diocese is an
hj-erarchial church, meaning.: i-) each parish consists of members of
The Episcopal Church confirmed in or transferred to that parish,
who are ín communion with the Bishop and the parisfr reing in union
with the diocesan convention; 2) each parish exists by virtue of.íts creation by the Bishop and the dj-ocesan conventioni 3) each
parish is sunjeåt to the jurisdiction of the Bishop and the
constÍtution of the diocese; 4) the go¡zernment of the parish is
subject to review and control of the Bishop and" diocesan
institutions in various important particulars, including the use of
real property used for religrious purposes, including those pursuant
to Canon 30; 5) Iegal title to.such real property is reposed in the
Diocesan Corporation rather than in the parisht and 6) priests and
d.eacons serving in the parish either are ordained. pursuant to
approval of rliocesan bodies and the Bishop or, havíng been ordained
PLAI NTI FFS' F I RST .AMENDED ORI.GI iIAL IjE]JI ION AND AP¿LIIAII Q}¡ fq8TEMPORARY INJUNCTI0N AND PERMANENT INJUNCTIQN - Pase 5 of 1ó
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in anotber diocese of The Episcopat Church or other church with
which the Dj-ocese is in communion, may become canonicalty resident
and serve in the Diocese as a priest or deacon only with the
consent of the Bishop. Under the Constitution of the Diocese and
under Canon 1aw, no person tnay be a membef of a parish. whro is not
a member of the npiscopal Church, and no person may serve on the
vestry of a parish who is not a member, cänonically resident, in
that parish. F'urther, no parish which is affiliated with the
Àntioclrean Orthodox Church can be in union with ,the Convention of
the'Diocese.
I0. HoJ-y Apost]es v/as initially organized as a non-self-
supporting mission of the Diocese on June 12, Lg64. Both the
Diocese and .4.11 Saints.' Church, a parish of the Diosese for many
years, gave Holy Àpostles financial assistance both for its
operating budget and for the acquisition of real property on which
to build. a church. Suctr real property was sold.on March 3-5, L986
and the sale proceed.s v/ere used in acguisition of the Real Property
described on Exhibit rtArt on which the parish's improvement are
presently located^. The funds provided by the Ðiocese and .by Â.1-1
Saints, Church viere gifts to Hoty Aposttes, rather than loans, and
rnrere never repaid. Holy Apostles has also received financial
assistance ín the form of a foan from the Crump Fund for
construction of improveinents on the neal- Property, saíd loan being
made at a below-market ínterest rate of 28 per annum. The Crump
Fund by iÈs trust indenture may lencl only to Episcopal parishes,
pLATNTTFTS¡ ffBgJ /\r.lENDËp 0RIGINAL PETITlTEHP0BARY INJUNCTION.AIID PERMANENT INJUNCTToN - Page ó of 1ó
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and such below-market foan conveyed a substantial benefit for which
Holy Apostles would not qualify otherwise and used Crump moneys
which woul-d have otherwise been avail-able to some other EpiscopaÌ
parish. Holy Apostles was admitted to the diocesan convention as
a parish on October 6, 1-979.
11. Defendant McCauley shared with many other Episcopalians
.a deep dissatisfaction v¡ith the policies of The Episcopal Church
but, unlike the teadership of the Diocese, he determined to leave
The Episcopal Church rather than to work for its reform. He
gradually acquired a Vestry uncanonicalfy and unl-awfully elected by
plurality rather than majority vote, which assisted his enterprise.
In early 3"gg2 | Defend.ant McCauley began a public campaign to lead
parishioners of HoIy Apostles into the Antiochean Orthodox Church.
Efforts by the Bishop and by other members of the Dj-ocese to
dissuade Defendant McCauley and the unlawfully constituted Vestry,
were unsuccessful. At the conclusion of two services on Sunday,
October 4 , ,1-gg2.t the Senior Warden announced to the parishioners
that at 7:00 that morning, the Vestry had unanimously voted to
leave The Episcopal Church and to petition to affiliate vrith the
Antíochean Orthodox Church. At one service on October 4, L992,
Defendant McCautey made such announcement. Defendants McCauley and
eleven of the twelve members of the Vestry thereby abandoned the
communion of The Episcopal Church and ceased to be qualified to
serve as a priest or as a member of the Vestry under the
Constitution and Canons of the Diocese and of The Episcopal Church
PLAINTIFFS' FI AMFNDFD ORIGINAL PETITION AND APPLICATION FOR
TEMPORARY INJUNCTION AND PERMANENT INJUNCTION - PAgE
HOLY/ 1 - 1A,/PSL
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I
and canon }aw. Defendant McCaul-ey has subsequently, on November
29, Lg92 | been reórdained as a deacon, and the el-even vestry
members and the members of the parish \dere chrismated as members of
the Antiochean orthodox Church on December 13 , 1992.
:-2. On October 5, Lgg2, pursuant to canon ]aw, the Bishop
reported these events to the Standing Committee of the Diocese"
The Standing Committee, having ascertained and considered the
facts, determined by a vote of at feast three-fourths of its
members that Defendant McCauley had abandoned the communion of The
Episcopal- Church and of this Diocese. A copy of such determination
by the Standing Committee is attached hereto as Exhibit rrB'r and is
hereby incorporated by reference. The Bishop thereupon affirrned
such' determination by the Standing Committee and inhibited
Defendant McCauley from officiating in the Diocese. A copy of such
inhibition 'is attached hereto as Exhibit rlCrr and j-s hereby
' ' Upon such inhibition the office of theincorporated by reference.. '
Rector of Holy Apostles became vacant, and the Bishop became Rector
ex officio
13. Having been informed that the unlawfully constituted
Vestry of HoIy Apostles had abandoned communion with The Episcopal
Church, oD October 5, Igg2, the Bishop sorrowfulfy accepted and
acquiesced in their abandonment of communion with him and thereupon
pronounced each lay member of the Vestry excommunicate. The Bishop
thereupon further pronounced that aII vestry offices of Holy
Apostles are vacant, since a1I members of the Vestry had abandoned
IN P
TEMPORARY INJUNCTION
HOLY,/1-1A,/PSL
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their qualification to hold such office under canon ]aw.
Subsequently it was l-earned that one member of the Vestry, Robert
Rigdon Ìrad not. particÍpated in such actions, and the pronouncement
of excommunication rìras ineffective as to him, Canonical procedure
commencêd to accept Defendant McCauley's abandonment of communÍon
and to depose him as'ipfiest. Pend.ing such proceeding, Defendant¡ 'ît-
McCauJ-ey resignäd'tïi= "..ministry as priest on November 26, lgg2,
which resignation was accepted on December 7, Igg2.
1,4. On October 5 r L992, Lhe Bishop caIled a special rneeting
of the parishioners of Holy Apostles for Sunday, October 11, a992'
to fill- the vacancies on the VesLry and to cal-l an interim Rector.
At such election, Robêrt Rigdon, Ann Heinz, He)-en Magnusson, Dave
Huêbnerr IVan Shadwick, and Charra I,rTright, \ifere elected to the
Vestry and contínue Èo serve as suckr. The Senior Warden is Robert
Riqdon and the Junior Warden is George Komechek. Subseguentlyr at
their yearly meeting on January 1-O I lrgg3, Georg:e Komechek, Ted Roe
and Doris Boyd r/ùere also elected to the Vestry. The Rev. Canon
James P. ÐelaTolfel Jr. has accepted a cal-t as Interim Rector'
Unless the Court grants injunctive relief, it will be necessary for
the parÍ-shionêrs of HoIy Apostles to meet at another location,
which condition will continue for so long as they are deprived of
the possession of the Real Property and the improvements,
furníshings and fixtures thereto. It is cornmonly and normally the
case that, where a local church are uprooted from their accustorned
place of meeting, such disruption causes a loss of membership which
HOLY/1 . 1 À/PSL
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may never be fully repaired. Consequently, the denial to the loyaI
parishioners of HoIy Apostles of the use of their real and personal
property, will cause damages to Holy Apostles for which there is no
adeguate rernedy at Iaw, so that a temporary injunction should issue
preventing interference by Defendants. with the loya1 parishioners'
possession of the Real- and other Property;
1-5, On October 5, Igg2, demand \,Jas made on Defendants for
uncontested possession of the ReaI Property and. improvements of
Holy Àpostles. Such demand was refused'
l-6. Many of the loyal'parishioners of golY Àpostles have
pointed out their' financial contributions and in addition the
special, unique furnishings and fíxtures given by them as memorials
to Holy Àpostles and. have noted that it was never their intent that
suctl gifts and mem<¡ría1s be converted to the use of the Àntiochean
Orthodox Church
:-:Z, Those persons acting in concord. with the Defendants have
constítuted themselves as the Schisnatic and Purported Church of
the HoIy Apostles. Sush personÊ are not members of the true Church
of the Holy Apostles because they have joined the Antiochean
Orthodox Chursh and thereby have abandoned communion with The'
Episcopal Church, and such Schísmatic and Purported HoIy Àpostles
is not in union with the Diocese; all as required by canòn law.
The Schisrnatic and Purported Church of the Holy Äpostles is a new
creation, having no relation to Hoty epostles and no right to its
property
pLAr ilT r FFs, F I RSr AMENg-Ep .
oR I c I ttAL PETI r iQN ANp-4PPL[ !4IJ gf'ljeBl¡¡goRARY tt¡JUNqTloN AÑ.0-.ÞEnuAxE{I Il!!!!Jl ' Pase 10 of 1ó
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Recommended