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Part 4

CONTINUATION OF CROSS-EXAMINATION OF PLAINTIFF WITNESS,

REV. BAZYL ZAWIERUCHA,

BY MR. SMORODSKY:

 

 

      A. In these Points of Agreement, I don't see the word.

P.46   Q Are -- and do the bishops of the Ukrainian Orthodox Church of the United States, are they directly elected by and are

           responsible to the Patriarch of Constantinople?

A.   Well, these particular bishops have not been elected nor have they been consecrated by the Ecumenical Patriarch, the three

     that presently -- well, they are bishops who have not been elected nor consecrated by the Ecumenical Patriarchate.

     Q. Have they been elected to the Church of the Patriarchate of Constantinople?

     A. They were received under the omophorion and they received the Holy Chrism from the Ecumenical Patriarchate which is a

          sign of the unity with that Patriarchate.

     Q. Let me ask you this question: Does Archbishop Antony, has he been elected to the position of Archbishop of Hierapolis,

          something like that?

     A. That is his titular title.

     Q. Is he a member of the Synod of the  Ukrainian Orthodox -- sorry -- of the Greek – strike  that. Is he a member of the Snyod

         of Bishops of  the Church of Constantinople?

     A. Yes, he's attended meetings there.

     Q. Father, prior to the Points of Agreement, was anyone that was a member of the clergy of the Ukrainian Orthodox Church of

          the United States of America permitted or had the opportunity to co-celebrate the liturgy with a member of the Church of

          Constantinople?

     A. Permitted by us or by them?

     Q. By them.

     A. Because I know that Patriarch Mstyslav – by them, I've heard, I've heard of some instances where our clergy did concelebrate

          in various parts of the country with ecumenical Orthodox clergy gatherings, so --

     Q. At ecumenical clergy gatherings?

     A. Such as Sundays of Orthodoxy, vespers, even divine liturgies before the Points of Agreement. I do know some instances.

     Q. Could you give me a specific example?

     A. Now, again, not witnessing but hearsay.

     Q. Hearsay. Well, do you know of your own knowledge whether there ever was a co-celebration of liturgy with the Greek, with

         the Patriarch, a church -- under the Patriarchate of Constantinople where the clergy of one church co-celebrated with the

         clergy of another?

     A. Prior to the Agreement?

     Q. Prior.

     A. It's difficult to say, but my knowledge is not that deep and extensive.

     Q. You don't know?

     A. I don't know.

     Q. Prior to 1995, did the clergy of the Ukrainian Orthodox Church of the United States of America co-celebrate the liturgy with

          members of the Ukrainian Autocephalous Orthodox Church in Ukraine?

      A. Yes.

      Q. They did, did they not?

      A. Yes, they did.

      Q. Now, after 1995, can a priest or clergy co-celebrate the liturgy with anyone or any church in Ukraine?

      A. We have -- it was expressly stated by the Metropolitan, the Prime Hierarch at the Sobor – I distinctly remember this -- in

          1998, and the last one, that indeed we could, if we were to travel to Ukraine, we could concelebrate with any priest of the

          Ukrainian Autocephalous Orthodox Church.

      Q. Let me ask you this question: This was at the Sobor in 1998?

      A. I remember this.

     Q. Yeah. And there was a -- you know who Reverend Partykevich?

     A. Yes, I do.

     Q. And Reverend Partykevich, he is the historian of the Ukrainian Orthodox Church of the United States of America?

     A. One.

     Q. And do you recall him standing up and asking whether anything has changed?

     A. I recall something, yes. Yes, I do.

     Q. And you recall --

     A. Yes.

     Q. -- at that time Metropolitan Constantine said directly to him, you may not co-celebrate, but in your case I'm making an

          exception?

A.   I don't recall that.

      Q. Okay. I show you what has been marked D-55. Can you take a look at those documents, please?

     A. What am I looking at?

     Q. Do you recognize these documents at all?

     A. No, I do not.

     MR. SMORODSKY: Your Honor, for the record I just would like to --

     A. I don't --

     Q. You don't recognize these?

     A. No.

     MR. SMORODSKY: D-55, for the record, are  letters or documents produced by the -- were produced by the plaintiffs during

     the course of discovery. There are three letters that in the course of discovery were represented to be statements made by the

     Bishop -- by the Archbishop -- strike that -- by the Patriarch of Constantinople, remarks made in 1995 to Bishop Antony and

     Metropolitan Constantine when they were elected into the Synod of Rome, the Synod of the Bishops of Constantinople.

     MR. REHILL: If Mr. Smorodsky intends to offer this as an exhibit, I am sure he is going to have somebody testify about it. I

     don't remember what it is. It's not one of the pre-agreed upon exhibits, and I couldn't know what it is. The witness has never

     seen it.

     MR. SMORODSKY: Fine.

     THE COURT: Well, let's need to have it -- the Reporter mark it for identification.  (Marked D-55 for identification.)

     BY MR. SMORODSKY:

     Q. Father Zawierucha, do you know who is Dr.  Lewis J. Patsavos?

     A. No, I do not.

     MR. SMORODSKY: Letter to Mr. Robert A. Hedesh, dated July 19, 1999, signed by Dr. Lewis J. Patsavos. And it was, and I

     will represent to the Court, marked as exhibit X filed by the plaintiffs on October 27th, 1999, in the first Motion for Summary

     Judgment.

     Q. Father, you testified earlier as to the paragraphs of Article One, section -- paragraph two, Article One, paragraph two, which

         is the autocephalous paragraph. Has that phrase been continually in the Ukrainian Orthodox Church Constitution going back

         all the way back to the 1920s?

     A. From those constitutions that I have seen, it has been.

     Q. What is the relationship at the present, in 19 -- strike that. Prior to 1995, what was the relationship of the Ukrainian Orthodox

          Church of the United States of America to the Patriarchate of Kiev in the Ukraine?

     A. The first Patriarch to be elected of Kiev was the Metropolitan of the Ukrainian Orthodox Church of the U.S.A., so --

     Q. What was the relationship as you understood it?

     A. -- as I understood it.

     Q. Yeah. I'm sorry. Before you answer --

     A. Forgive me. I'm trying to, you know.

     Q. Gather your thoughts?

     A. Gather my thoughts.

     MR. REHILL: Can I interfere with that thought process? I am not sure that I understood the questions. Has he understood it

     when? As he understands it now? As he understood it when the Patriarch Mstyslav was elected Patriarch?

     MR. SMORODSKY: Let's break it down. I'll withdraw the question.

      Q. Father, you testified earlier that you studied oriental religions-- oriental, orthodox, and Christian religions, correct?

      A. Yes.

      Q. And you teach the history of the Church at the seminary, correct?

      A. One course.

      Q. One of the courses. And you have some knowledge of the various histories of these churches, correct?

      A. Yes.

      Q. As a matter of fact, if I'm not mistaken, your testimony is that you were a participant in discussions directly with the Patriarch

           Mstyslav regarding his becoming the Patriarch of the Ukraine?

     A. That one phrase.

     Q. That one phrase. And you were present when these events occurred, correct?

     A. I was present in America.

     Q. In America?

     A. Yes. I was not there.

     Q. What was your understanding at that time as to your relationship -- by "your" I'm referring to the Ukrainian Orthodox Church

          of the United States -- what was your understanding was the relationship of the UOC-USA to the Patriarchate of Kiev?

A.   Well, Patriarch Mstyslav, Blessed Memory, was alive, my understanding was the following, and it was that he was the

     Patriarch of Kiev and all Ukraine, but that he made a point of stressing that he retained also his title as Metropolitan of the

     Ukrainian Orthodox Church of the U.S.A. in order for it to retain its internal structures undisturbed.

     Q. Now, the Ukrainian Orthodox Church of the Ukraine -- of the United States of America participated in the Sobor and in the

          voting that occurred for Mstyslav or his Beatitude Mstyslav to become Patriarch, correct?

A.   Some members of the Church did.

     Q. The UOC-USA directly had representatives there and participated in it, correct?

     A. Yes, I gather that was the case.

     Q. Do you have any knowledge of what the Sobor or the highest organ of the UOC-USA considered the relationship to be --

     A. I'm sorry. I do not clearly have that in mind.

     Q. After Patriarch Mstyslav passed away, did anyone from the Ukrainian Orthodox Church of the United States of America,

         candidate to become his successor?

     A. I do not know that.

     Q. Father Zawierucha, you testified as to the structure of the UOC-USA, and you made reference to the chart.

     A. As a tool to help.

     Q. As a tool. As a help.

     A. Yes.

     Q. Would it be fair to say that your exhibit has some missing parts to it as opposed -- with regards to the role of the Ecumenical

          Patriarchate?

A.   I -- it's not obviously -- it's not there.

Q. And there is a relationship, correct?

     A. There is an intimate relationship with the Ecumenical Patriarchate. Sacramentally.

     Q. I am sorry?

     A. Forgive me. Sacramentally.

     Q. Sacramentally?

     A. Yes.

     Q. But the Points of Agreement indicate who elects the bishops.

     A. Bishops are consecrated, too, so there is a sacramental -- that is the most important.

     Q. What does paragraph six of the Points of Agreement say?

     A. You wish me to read it through?

     Q. Yes. Again.

     A. "The Primate or Acting Primate of the Ukrainian Orthodox Church in the U.S.A., after consultation with the Exarch of the

           Ecumenical Patriarchate in America, shall submit a slate of candidates for the office of the Metropolitan and bishops to the

           General Council, Sobor, of the Ukrainian Orthodox Church in the U.S.A. for approval in the first instance. The names of

           those candidates so approved shall then be submitted to the Holy and Sacred Synod of the Ecumenical Patriarchate for

           canonical election."

     Q. What do you understand the phrase "canonical election" to mean?

     A. That is a very important phrase.

     Q. Yes, it is.

     A. Yes. A serious phrase.

     Q. Yes.

     A. As I said to you previously, that Article One, paragraph two of the Constitution has an internal contradiction within it, and it's

         pretty obvious. When we speak of the Ukrainian Orthodox Church of the United States of America keeping the dogmas,

         canons, structure and worship of the Holy Ecumenical Orthodox Church, then its autocephaly should also fall under that. So -

     Q. Go ahead.

     A. -- so, therefore, we have from the Points of Agreement that the candidate is elected by the Sobor and is then passed on for

          canonical election to the Ecumenical Patriarchate in order to preserve the canons, dogmas, structure and worship of the

          Orthodox Church.

     Q. Do you know if that language was in all of the constitutions from the beginning of the Ukrainian Orthodox Church of the

          United States of America in the 1920s?

     A. Again, I didn't remember -- read.

     Q. You didn't go back to the 1920s?

     A. I didn't go back all the ways, as I said previously, to read those from 1920s, so, the 1963 Constitution speaks of this, too.

     Q. With regard to Canonical Election, did prior to 1995, did the Ecumenical Patriarchate treat the bishops of the Ukrainian

          Orthodox Church as non-canonical?

     A. Treat them? Regard them I would say better maybe.

     Q. As non-canonical, correct?

     A. In the strictest conformity to the canons of the Church, they were validly consecrated if that's -- please, we can't confuse the

          two.

     Q. I want you to use the term as you understand it, and then if you wish you can explain how you understand that term.

     A. That's indeed they are -- they were and always have been validly consecrated and ordained hierarchs in the Orthodox, Holy

          Catholic Ecumenical Orthodox Church, yes, but was the -- a direct link and canonical linkage  to the Ecumenical

          Patriarchate, it was very vague.

     Q. Father --

     A. You see --

     Q. Go ahead. Please explain. I'm sorry for interrupting.

     A. I can't explain it. I mean --

     Q. You cannot explain it, correct?

     A. No, I'm not -- not very clearly.

     Q. Do you know the difference?

     A. There was -- let's put it this way: There was some Orthodox churches that regarded our church prior to 1994 regarded to be

          non-canonical, yes.

     Q. And among those churches was the Ecumenical Patriarchate of Constantinople, correct?

     A. In the strictest sense, yes, correct.

     Q. They did not co-celebrate the liturgy?

     A. Usually, no.

     Q. Correct?

     A. Not with our hierarchs.

     Q. Not with your hierarchs?

     A. There may have been, as I said, some clergy who did, but again, that is speculation. I don't know.

     Q. You don't know. That's pure speculation?

     A. It's again what I've heard.

     Q. Now, by co-celebrate liturgy, what do you understand that phrase to mean?

     A. That we all share in the same body and blood of Christ as Orthodox Christians and that is the Eucharist. The body and blood

          of Christ is the sign of our unity.

     Q. Now, that would mean -- correct me if I'm wrong -- that co-celebration specifically refers to priests of one church or

          hierarchs of one church and hierarchs of another celebrating the liturgy, the Eucharist, what the Latins call the Mass, together

          at the same altar, correct?

     A. Yes.

     Q. That is to be distinguished from co-celebrating or being present at the same ecumenical event?

     A. Yeah. Gatherings.

     Q. Gatherings, prayer sessions, or anything of that nature, correct?

     A. Yes.

     Q. And that -- and that is the key distinction between recognition and non-recognition, correct?

     A. It is a key element within that, yes.

     Q. Now, since 1995 has anyone within the Ecumenical Patriarchate of Constantinople co-celebrated the liturgy with anyone from

          Ukraine?

     A. I do not know.

     Q. Since 1995, what is the relationship between the Ukrainian Orthodox Church of the United States of America and the

          Ukrainian Orthodox Church in Ukraine?

     A. Which one?

     Q. Any one.

     A. What has been the relationship? There have been constant contacts and fraternal greetings and letters back and fort constantly

          with various hierarchs, priests, Orthodox priests and hierarchs in Ukraine.

     Q. Any co-celebration?

     A. Again, I do not know this.

     Q. Any structural relationship?

     A. Structural --

     Q. In any way that you recognized the Church in Ukraine?

     A. Well, of course, you do understand that the Ukrainian Autocephalous Orthodox Church in Ukraine at one point -- I don't

          know what the situation of it is presently -- recognized Metropolitan Constantine as the head of the Sobor of the Synod, so

          there was a very close relationship.

     Q. Then what happened?

     A. I don't know.

     Q. Oh?

     A. No, I seriously do not know.

     Q. Okay. I understand. You are the Director of the Seminary?

     A. I am the Administrator.

     Q. The Administrator. Are you familiar with the Certification of Incorporation of your entity?

     A. I don't know it by heart. If I saw it, I would be aware of it. (Marked D-102 for identification.)

     Q. I show you this document. Would you please take a look at it and tell me whether it refreshes your recollection.

     A. Yes, I have seen this document. It does look familiar.

     Q. Now, take a look, I think it's paragraph two, the purposes clause.

     A. Forgive me. In the Constitution?

     Q. In the -- in the Certification of Incorporation.

     A. This one here?

     Q. That's correct.

     THE COURT: Could we identify the document for the record?

     MR. SMORODSKY: For the record, Certification of Incorporation of St. Sophilia Ukrainian Orthodox Seminary, Inc., in New

      Jersey, a New Jersey nonprofit corporation, filed February 15th, 1991.

     Q. Now, paragraph two, that paragraph indicates the purposes why your seminary exists, correct?

     A. It does say the purpose for which, yes.

     Q. And is the purpose to create or to teach seminarians with regards to becoming priests in the UOC, Autocephalous Orthodox

          Church of the United States of America?

 A. The corporation organized to provide it does say Ukrainian Autocephalous Orthodox Church in the United States of

     America, Ukraine, and the diaspora with qualified priests, pastors --

      Q. Comma --

      A. Comma.

      Q. Ukraine, comma --

      A. Comma.

      Q. -- and the diaspora with qualified priests, pastors, etcetera. Now, has that mission statement of your corporation changed?

      A. No.

     Q. Do you provide --

     A. Not on paper. No, not in any way.

     Q. I'm sorry. I didn't --

     A. Not in any way on paper. No, the mission statement stands.

     Q. How about in reality; has the mission statement changed?

     A. No, not in reality.

     Q. Do you still provide seminarians to Ukraine?

     A. The last to Ukraine you mean?

     Q. To Ukraine.

     A. If there were candidates, certainly we would.

     Q. And have there been any candidates?

     A. From Ukraine you mean?

     Q. From 1995 on.

     A. We have had certainly candidates from Ukraine who are now resident in the United States go through the seminary, yes.

     Q. And they stayed here with the UOC-USA, correct?

     A. Some were ordained, some were not.

     Q. Did anyone –

     A. Return?

     Q. -- return to the Ukraine from 1995?

     A. No, no one returned to the Ukraine.

     Q. Now, is that because your church became a part of the Ecumenical Patriarchate of Constantinople?

     A. Forgive me. I don't think so.

     Q. Now, going back to the structure on your sketch, you have a pyramid structure, and your testimony was that the parishes are

          responsible to the Deanaries, who are then responsible to the Eparchies, who are then responsible to the Consistory?

     A. No. The parishes, more direct link is to the Consistory, but also to the Eparchial Bishop.

     Q. The parishes, their role, you do not claim -- the parishes, they have absolute right to all of their property, correct?

     A. That's what it says in the Constitution.

     Q. And in your studies along the way about the Ukrainian Orthodox Church in the United States of America, was there any

          slightest claim that the bishops or the Consistory have any type of control or influence on the property?

     A. Not that I'm aware of.

     Q. Okay. You testified that the Constitution of 1998 appoints and directs who the clergy are to be at the parishes, correct?

     A. Yes. It's in here.

     Q. Do the parishes have any role at all in electing, selecting, or appointing?

     A. The phrase that I found was that they have a role in submitting a preference for someone, certainly.

     Q. Basically a preference, correct?

     A. Yes. They would request a certain priest, a certain clergyman from -- request from the Consistory.

     Q. Now, that paragraph of the Constitution of 1998 that you are referring to --

     A. I hope I can find it immediately.

     Q. Try.

     A. Try? Okay. Here we go. Yes.

     Q. Which paragraph is it?

     A. Would you like me to read it? It is paragraph 11 of Article 11.

     Q. Is that paragraph 11 --

     A. No. 11 of -- sorry. Of 12. Article 12.

     Q. Of article 12?

     A. Uh-huh.

     Q. Is that any different than what existed in 1963?

     A. Again, from memory?

     Q. Yes.

     A. I can't -- I truly can't remember specifically.

     Q. How about 1950?

     A. That I don't know.

     Q. Now, do you know what was the practice from 1950 until now in appointing parish priests or pastors?

     A. The practice I do know is what I know since I entered the Church, the Ukrainian Orthodox Church of the U.S.A.

     Q. And that is since 1991?

     A. '90ish, '90.

     Q. Now, is there a paragraph in the Constitution that says that the Consistory must keep records of its actions?

     A. I'm -- I can't remember. But shall we discover that?

     Q. That may be interesting.

     A. The Consistory does keep records obviously.

     Q. You are a member of the Consistory, correct?

     A. Yes.

     Q. And I think if you look under the paragraph that governs the duties of the Consistory you'll find it in there.

     A. I am. Yes. There is, indeed. Are you specifically meaning reference to records of clergy?

     Q. Records of --

     A. Clergy.

     Q. Yes.

     A. Yes. It does say to keep the register of the clergy and clerics, parishes and faithful.

     Q. To keep the records of the parishes, correct, the register of parishes?

     A. The register of the parishes and the faithful.

     Q. You are a member of the Consistory, correct?

     A. Yes.

     Q. And the Consistory does have records about its relationships with the priests over the years, correct?

     A. I'm sure I would keep those, yes.

     Q. And those documents are the ones that will have the history of how the appointment of priests at parishes actually occurred,

          correct?

     A. I would assume so. I haven't seen them.

     Q. To your knowledge, do you know what the practice of appointing priests to parishes was before you came to the Church?

     A. Again, only on hearsay.

     Q. Nothing of your own knowledge?

     A. Not prior to my entering the Church.

     Q. Now, you testified earlier that there is a paragraph in the Constitution of 1998 that requires parishes to register their

          constitutions, correct?

A.   With the Consistory, yes.

Q. With the Consistory?

     A. Yes.

     Q. And you also mentioned the fact that the Constitution requires the Consistory to keep records of its registered parishes,

         correct?

     A. Yes.

     Q. To your knowledge, has the Consistory registered constitutions of the various parishes?

     A. Of those parishes that have submitted their constitutions, they have, and they keep encouraging, the Consistory I mean, keeps

          constantly encouraging, through the pastors of those parishes and by mail, for the rest to submit their constitutional bylaws

          for approval.

     Q. That paragraph of the Constitution that requires registration is the same paragraph that was in the Constitution in the 1963,

          correct?

     A. That I seem to remember to being correct.

     Q. It was also the same thing that was in the Constitution in 1950, correct?

     A. I don't know.

     Q. You don't know?

     A. I don't know that.

     Q. Now, your testimony was of those parishes that submitted their constitutions, they would review them, correct?

     A. I assume they would. I must tell you that since I have been a member of the Consistory since the last Sobor we haven't

          reviewed any parish constitutions --

     Q. Now --

     A. -- so I don't know what the actual --

     Q. You don't know what the actual practice is?

     A. No. I mean, the procedure, how this is done.

     Q. Have there been pastors that refuse to submit their constitutions?

     A. That I don't know.

    Q. Does the Constitution of the UOC-USA provide for remedy for those who violate that Constitution?

     A. I would need -- I don't -- offhand, I can't remember what the remedy there is.

     Q. Is the remedy expulsion of the parish?

     A. For that particular reason?

     Q. Yes.

     A. Well, based on practice, no, because no parish has been expelled for that reason.

     Q. Why haven't they been expelled?

     A. I don't know.

     Q. You don't know?

     A. I don't -- no, I don't -- not to mean I don't know why they should have been expelled. I mean I just don't know. No one has

          been expelled.

     Q. And are there parishes who have submitted their Constitution that have provisions that are contrary to that of the --

     A. I do not know.

     Q. You do not know. But all these records are available within the Consistory, correct?

     A. They are placed in the Consistory.

     Q. And you could review them as a member of the Consistory, correct?

     A. I would assume I could.

     Q. Now, you testified on direct that one of the remedies that the Consistory has for a parish violating its obligations under the

          Constitution is to expel it, correct?

     A. That is a possibility.

     Q. What other possibilities are there?

     A. Reminders, constant nagging, you know, fraternal Episcopal requests. It's rather, you know, we are a soft bunch.

     Q. It's mostly requests?

     A. Yes.

     Q. Cajoling?

     A. Encouragement.

     Q. Encouragement?

     A. Fraternal outreach.

     Q. Nothing other than that, correct?

     A. No, not that I've witnessed, not that I've seen.

     Q. Not that you know of, correct?

     A. I don't know of an instance where a parish has been expelled.

     Q. Do you know of an instance -- well, let me ask you this: Is there provision in the Constitution that permits the Consistory to

          suspend?

     A. I never saw that word, suspend.

     Q. Okay. Now, there is no definition in the Constitution of what the term "suspend" means or it being provided as a remedy,

          correct?

     A. I haven't seen the word, no.

     Q. In the Constitution, the right to expel a parish has always been there from 1998 to 1950, correct?

     A. Again, I haven't read the 1950 Constitution.

     Q. How about '63?

     A. '63 I remember.

     Q. Okay. And it's in there?

     A. Yes.

     Q. The Constitution of the UOC-USA also has a provision that the parishes must file an annual report?

     A. Yes, it does.

     Q. And correct me if I'm wrong. The annual reports are reviewed by the Consistory --

     A. Yes.

     Q. -- to determine whether or not the actions being taken by the parishes is in conformity?

     A. Well, for the health, spiritual health of the church, of the parish, yes.

     Q. Now, if the annual report showed something happening with property, the Consistory wouldn't change -- wouldn't do

          anything about it, right?

     A. Again, the property belongs to the parish.

     Q. If they passed a constitutional change, would the Consistory do anything about it?

     A. If they did?

     Q. Yes.

     A. Who is that? The parish you mean?

     Q. Yeah. The parish adopted a constitutional change that did not comply with the Consistory position.

     A. With the Constitution of the Church?

     Q. Right. Right. Would the Consistory have a right to do something?

     A. Can I refer to reasons for expulsion, if that is what you are referring to?

     Q. Well, expulsion, sure.

     A. I don't know. Well, it does specify.

     Q. Refer to anything you need.

     A. It does specify reasons for expulsion here.

     Q. Of a parish?

     A. Of a parish, yes.

     Q. Take a look at that paragraph.

     A. Okay. I think it's under Consistory. No. It speaks of under Consistory, article six, paragraph three, subsection H, that the

         expulsion of parishes that should fail to comply with the provisions of the present Constitution. The Ukrainian Orthodox

         Church of the U.S.A. shall be carried out in accordance with the decisions of the Consistory, approved by the Metropolitan

         Church Council.

     Q. And one of the requirements of the Constitution of the UOC-USA is that its, the parishes' constitutions conform to that of the

          UOC-USA?

     A. It is a requirement of the Constitution.

     Q. And that is the power that the Consistory has for violation of that provision, expulsion, correct?

     A. I would seriously doubt whether they would expel a parish for that reason alone. But nobody has been expelled, so there is no

          precedent yet, that I can think of.

     Q. Now, Father, we're coming to the end.

     A. Thank you.

     Q. You're welcome. The Consistory has under its control all of the record-keeping of the Ukrainian Orthodox Church of the

          United States of America, correct?

     A. That's where it's placed.

     Q. And the head of the Consistory is Archbishop Antony, correct?

     A. Presently, yes.

     Q. And he has been the head of the Consistory from at least 1995, correct?

     A. The President of the Consistory, yes.

     Q. Does -- do the historical records contain records relating to the various Sobors that took place?

     A. The minutes you mean?

     Q. Minutes, whatever, notes.

     A. Minutes certainly. Yes.

     Q. Documents?

     A. Documents presented at the Sobor, yes.

     Q. Would have the personal correspondence of bishops?

     A. The Consistory?

     Q. Yes.

     A. You know, I don't know that. I don't know who would keep those personal correspondences. If they are in the archives,

          eventually they end up there.

     Q. And the archives are under the control of the UOC-USA, correct?

     A. Yes, yes.

     Q. Those archives would also have correspondence between the Consistory, the bishops, and the various parishes?

     A. I would assume they do, since history needs to be written eventually.

     Q. And that history that's being written is something that Mr. Partykevich --

     A. Yes, he is.

     Q. -- is undertaking?

     A. Presently.

     Q. And actually he wrote a very extensive article in the Ukrainian Orthodox Word indicating the volumes of documents that are

          presently in his possession?

     A. I seem to remember that.

     Q. Is that correct?

     A. Uh-huh. Not in his possession; that he has access to.

     Q. Access to in the possession of the --

     A. Consistory.

     Q. -- of the Consistory. Are you at all familiar with a hierarch that was known as Bishop Mark?

     A. No, I'm not. I think he passed away before I entered the Ukrainian Church.

     Q. Have you reviewed or looked at any documents relating to the parish in Carteret?

     A. No, I have not.

     Q. Those documents relating to the parish in Carteret, which is a member of the UOC-USA is located -- the registry and

          documents relating to that parish may be available at the UOC-USA?

     A. I would hope I could help you with that more concretely. I would he assume they are, yes.

     MR. SMORODSKY: Let me just go through my notes, your Honor, if I may.

     MR. SMORODSKY: I have no further questions.

 

Next Installment:

Direct Examination by Mr. Smorodsky of defense witness

Professor Thomas E. Bird,

Queens College, The City of New York.

 

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