Bishop Accountability

Dallas Resources – November 1997

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Grand Jury Indicts Kos on 8 Sex-Abuse Charges
Suspended Priest Fails to Get Bail Reduced

By Michael Saul
Dallas Morning News
November 1, 1997

A Dallas County grand jury indicted suspended Catholic priest Rudolph "Rudy" Kos on Friday on eight sex-abuse charges involving four young men who told police they were molested more than 1,350 times.

Mr. Kos, 52, pleaded not guilty to each of the charges during two arraignments in October.

But Irving police Detective Randall Johnson said during a hearing Friday that Mr. Kos admitted the molestation to at least three people.

Mr. Kos also testified Friday for the first time since his arrest in an effort to persuade state District Judge Janice L. Warder to lower his bail. The judge ordered his bail to remain at $400,000.

Mr. Kos told the judge that several of his friends might be able to help him post bond if she reduced it to $5,000 on each charge.

He wore a white Dallas County jail jumpsuit, white socks and sandals and showed little emotion.

When asked by Assistant District Attorney Howard Blackmon why he used the name J. Rudy Edward while living in California, Mr. Kos said, "My father and I had a falling out. He turned his back on me.

I was also being pursued by the media. " Mr. Blackmon called Mr. Kos a "prototypical sexual predator" and the county's "worst child molester" in recent memory.

"He is a danger to this community. He is a danger to any community," Mr. Blackmon said in arguing against the bond reduction.

The charges allege that Mr. Kos abused the boys - who ranged from 12 to 16 - from the late 1980s to the early 1990s, when he was a priest at St. Luke's Catholic Church in Irving.

Two of the young men told police that Mr. Kos molested them as many as 400 times each. One told police that Mr. Kos molested him 550 times over seven years.

Mr. Kos was indicted on three counts of aggravated sexual assault of a child, one count of sexual assault of a child and four counts of indecency with a child. The aggravated sexual assault charges carry up to a life sentence and $10,000 fine on each count.

In four of the cases, Mr. Kos is accused of using the boys' feet to gratify himself sexually. In the other four cases, Mr. Kos is accused of performing oral sex on the boys.

Mr. Kos admitted the molestation to an insurance agent, a psychiatrist and one of the boys' parents, Detective Johnson testified. In an interview with the psychiatrist in 1992, Mr. Kos "estimates that he has been sexual with about 20 minors," records show.

Detective Johnson said he knows of no witness to any of the alleged abuse.

Mr. Kos' court-appointed attorney, Brad Lollar, said the lack of witnesses casts doubt on the case. "By the sheer volume that they are claiming, it would seem unlikely that it could have happened as often as they claim it did and not have a third-party witness," he said in an interview.

A second court-appointed attorney, Doug Parks, began work on the cases this week.

Mr. Lollar also questioned why the young men took so long to file criminal complaints since at least three of them have been involved in civil litigation involving Mr. Kos for several years.

Mr. Lollar also pointed out that no evidence was presented Friday to show that Mr. Kos coerced or threatened any of the boys.

"We didn't hear any evidence of any force," he said. "It appears they were consensual acts on the part of the complainants." But threat or no threat, Mr. Lollar acknowledged, any sexual contact with a minor is illegal.

Both Mr. Lollar and Mr. Blackmon declined Friday to discuss the possibility of a plea bargain. There have been no discussions, Mr. Lollar said.

At least one of the young men involved in the criminal case told police he was also molested multiple times while in Ellis County.

Detective Johnson said he plans to contact Ellis County law enforcement officials.

Mr. Kos had been free on two $5,000 bonds on two other sex-abuse charges when he was arrested Oct. 15 at a San Diego bar in connection with the eight new charges. The two older cases were dismissed earlier this week because they were beyond the 10-year statute of limitations.

Testimony in the bond-reduction hearing also included allegations that Mr. Kos molested a child when he was a juvenile, was abusive to his ex-wife and once gave a gun to a minor and told him to shoot his father "if he had the occasion to do so."

A civil jury found in favor of 11 plaintiffs and returned a $119.6 million judgment against Mr. Kos and the Catholic Diocese of Dallas in July - the largest clergy-abuse judgment in U.S. history.

The jury found that the church covered up the abuse and urged church leaders to "admit your guilt. " Mr. Kos never showed up for the civil trial. At its start, state District Judge Anne Ashby found him liable for the abuse because he never responded.

Jim Sibert, who is involved in the civil litigation but not the criminal cases, attended Friday's hearings with members of the complainants' families.

"I am very happy with what's happening," Mr. Sibert said as he left the courtroom.

School Chief for Diocese Says He Will Resign
He Tells Principals of Midyear Exit

By Brooks Egerton
Dallas Morning News
November 6, 1997

The controversial superintendent of schools for the Catholic Diocese of Dallas told a gathering of elementary principals Wednesday that he's leaving at the end of December.

The Rev. Leonard Callahan gave no reason for his midyear departure and asked the principals to keep it secret for now, sources told The Dallas Morning News .

Diocese officials said they hadn't been briefed on the announcement and had received no resignation notice. Diocesan school board members said they, too, were in the dark.

"That comes as a surprise to me," board member Edwin Schaffler said. "He and I haven't discussed it, and I consider him a friend.

"If he feels that he's not effective as a leader, then I can understand it. " Father Callahan, who could not be reached for comment, oversees about 40 schools and more than 10,000 students in the nine-county diocese - a larger operation than many North Texas public school districts.

In August, he was removed from Bishop Charles V. Grahmann's cabinet and stripped of his title as vicar for Total Catholic Education. Diocese officials said the change would allow Father Callahan to devote more time to building a new high school in north Plano, which is scheduled to open in 1999.

At the time, he declined to discuss the change "because I haven't had any conversations with the bishop. " Several weeks later, asked about rumors that he would be leaving before the end of the school year, he declined to comment.

He has made several controversial moves since becoming superintendent in late 1993 and later setting up the Total Catholic Education department, which put schools and other religious education programs under one umbrella.

One particularly sore spot was the replacement of some schools' elected boards with panels where half the members are elected and half are appointed.

In a 1996 interview with The Morning News , Father Callahan defended the change as part of a centralization plan aimed at serving all Catholic children, not just those who attend diocese schools.

A group calling itself Parent Advocates of Catholic Education has challenged the move away from site-based management. A spokesman, St. Pius X parishioner John Farrell, issued this statement about the superintendent's pending departure: "Father Callahan and his staff have been arrogantly unresponsive to the parents of children in Catholic schools. We are hopeful that this resignation is a precursor to a new openness and a policy of parental inclusion on the part of the bishop and his administration." Other problems have arisen over plans for the new Catholic high school, which would be the first built in the Dallas area in more than 30 years and the first north of LBJ Freeway.

A site selection committee recommended building in Richardson, seeking a midpoint between Plano and North Dallas. Father Callahan instead picked a site nearer the northern edge of suburban growth - too far north, some said, for many parents to drive in the morning before joining the southbound commute.

The new high school was scheduled to open next fall but was delayed a year by problems in developing the site, diocese officials have said. Neighbors have expressed concern about traffic, noise and athletic-field lighting.

The 1999 target date for opening is questionable, said Richardson parishioner Kathy Nelson, a parent who has been active in promoting the new school. Paperwork that was to have gone to the city of Plano in May is just now being submitted this month, she said, and a contractor isn't expected to be chosen until spring.

Ms. Nelson welcomed news of Father Callahan's departure, calling him "a brilliant man" who "doesn't take the time to listen.” Discontent with the superintendent, she noted, has coincided with strife over lawsuits alleging a coverup of child molestation by priests. More high-level resignations are needed to restore Catholics' faith in diocese leadership, she said.

"They all need to go," Ms. Nelson said. "Every single, solitary one of them."

Father Callahan has sought to reassure potential school donors that their money won't be swallowed by the $119.6 million judgment against the diocese in the case of suspended priest Rudolph "Rudy" Kos.

"I have no reason to think that it will change any plans," he told The Morning News in August. "Our moneys are separately incorporated, and every indication and all the advice that I've gotten is that our moneys are secure. "

One plaintiffs' attorney in the Kos case, Sylvia Demarest, said she doesn't believe the assets are separate. She stressed, however, that she doesn't plan to try to seize churches and schools.

In the August interview, Father Callahan said that $5 million had been raised toward the $14 million cost of the school's first phase.

Other controversies during the priest's four-year tenure:

* Extending criminal history checks and fingerprinting to all school employees, not just new hires. Father Callahan said the move was necessary to safeguard students; some employees and volunteers protested that priests weren't being fingerprinted at the time, despite molestation allegations against Mr. Kos and others.

* Making many staff changes. More than a dozen principals quit or were forced out in 1995-96; several other central-office administrators also left. Most left for better opportunities elsewhere, Father Callahan has said.

* Hiring a Kentucky associate in his mid-20s as assistant superintendent for finance and human resources. Parents complained that Father Callahan, 58, waived advanced-degree requirements for Douglas Hamilton but wouldn't do the same for a popular teacher seeking promotion to a principal's job. The superintendent responded that he had the right to make such decisions.

The diocesan school board is scheduled to meet Saturday. The agenda mentions nothing about the superintendent's plans to leave, board member Doris Dunkerley said.

"That's news to me," she said. "I'd be surprised that he'd say something before he talked to us. " Board members said they had expected Father Callahan to serve at least through the end of the school year.

Nun to Head Catholic Charities
Bishop's Appointee Will Be First Woman to Run Agency

By Brooks Egerton
Dallas Morning News
November 13, 1997

Bishop Charles V. Grahmann has named another nonpriest to a prominent position in the Catholic Diocese of Dallas, appointing Sister Mary Anne Owens as executive director of Catholic Charities.

Sister Owens will be the first nun and first woman to run the agency, one of the largest social-service providers in the Dallas area. It offers everything from child and elder care to immigration assistance, family counseling and adoption services.

"She was our overwhelming choice, to such an extent that we didn't employ a headhunting firm," said the Rev. Kilian Broderick, whom Sister Owens succeeds as executive director. "She has the right stuff."

Sister Owens is a member of the School Sisters of Notre Dame, a Dallas-based order, and has a record of service work dating to the late-1960s. She has been a principal at Catholic schools in Dallas and Fort Worth, a teacher in Maryland and Pennsylvania, a director of the Lafayette, La., diocese's peace and justice office and a member of her order's administrative team.

From 1994 to 1996, Sister Owens headed the Brady Center, one of several major Catholic Charities programs. The East Dallas center aids the poor with meals, recreation and health care, plus classes in citizenship, literacy and English as a second language.

For the last year and a half, the 53-year-old nun has helped care for her mother and worked to develop social-service ministries for a diocese on her native Long Island, N.Y. She's due to start work in Dallas in early January.

"We look forward to her return to Dallas because of her reputation for working tirelessly to help the poor and needy," Bishop Grahmann said in a written statement. He said she "symbolizes the great service that Catholic nuns have given here."

Sister Owens acknowledged that she is returning to Dallas at a difficult time for the diocese, which faces a huge judgment in the sexual-abuse case of suspended priest Rudolph "Rudy" Kos.

But "you have to go on with your work," she said. "The need is still there. The poor haven't gone away."

The $119.6 million jury award, she said, "has certainly called all the people I'll be working with to a new level of commitment. If anybody's there just for a job, that's not what it's about."

Sister Owens said she's hoping not to retrench but to expand Catholic Charities, whose $5.5 million budget comes largely from nondiocesan sources such as government, the United Way, service fees and donations.

"Welfare reform is a huge issue," she said. "The welfare-to-work people are going to need help. " Other challenges include the Dallas area's shortage of affordable housing and influx of immigrants, Sister Owens said.

Bishop Grahmann has made several personnel changes in the wake of the Kos verdict, appointing lay people to key boards and commissions. And he named Mary Edlund - the first woman top official in diocese history - to the new position of vice chancellor, a job that involves investigating complaints about priests.

"He wants to connect more with parishes," said Sister Owens.

Shortly after the July 24 verdict, the bishop also accepted Monsignor Broderick's long-standing offer to resign and return to full-time pastoral duties at St. Ann Catholic Church in Coppell.

The decision, officials maintained, was unrelated to a letter the priest wrote advising fellow pastors to protect their assets from the judgment. Diocese officials condemned the advice, with one saying that "we're not going to violate any laws as far as transferring things." Pastors have since hired their own law firm and contend - as the bishop does - that parish assets are separate from the diocese's assets and not subject to collection. Plaintiffs' attorneys disagree but say they hope not to disturb the work of churches, schools and charities.

Dallas Verdict Worries Bishops
Award in Kos Sex Abuse Case Stirs Talk at National Conference

By Deborah Kovach Caldwell
Dallas Morning News
November 17, 1997

Washington, DC - It's the topic bishops dread.

A decade ago, revelations of priest pedophilia plunged the U.S. Catholic Church into crisis. Then, just as the bishops thought the worst was over, a Dallas jury awarded the largest judgment ever in a clergy sexual molestation case.

The July verdict has stunned the Dallas Diocese. It has terrified bishops around the country. And it has put clergy sexual abuse back on the church's national agenda.

So as the 300-member National Conference of Catholic Bishops met last week in Washington, Bishop Anthony Pilla of Cleveland felt compelled to talk about pedophilia during his annual presidential address.

"We bishops regret deeply the harm that has been done to children and young people and which remains with them in adulthood," he said. "We pledge our continuing and constant vigilance in preventing such abuse."

Bishop Pilla's speech marked the first time in several years that the issue has been publicly addressed at the national meeting, although it was followed by no public discussion. His remarks seemed to reflect the concern heard privately among the bishops throughout the week.

Gathered in tight circles between sessions, they worried about the possibility that somewhere, sometime, another jury would award plaintiffs another huge sum.

Perhaps in their own dioceses.

On July 24, a jury awarded 11 plaintiffs $ 119.6 million after deciding that the Diocese of Dallas committed "gross negligence" and concealed information in dealing with suspended priest Rudolph Kos.

"The decision was unfair and the judgment excessive, and I hope justice will be done on appeal," said Archbishop Michael Sheehan of Santa Fe, a former priest in the Dallas Diocese. "It isn't fair to take the funds of the Catholic people and pay such an excessive award."

In 1993, Archbishop Sheehan moved from Lubbock to Santa Fe to repair a diocese where more than 165 pedophilia cases had been filed. He set up counseling for victims and settled insurance claims. Then he started a spiritual renewal program that he said has attracted nearly 40 percent of active church members.

"They say that the worse off a diocese is, the more successful a renewal program is," he said with a dry laugh.

In some ways, Archbishop Sheehan had it easy. His job was to come in and salvage an already traumatized diocese. Other bishops are dealing with problems that developed in dioceses where they have served for some time.

Since the Dallas judgment, many people have come forward with accusations, and more than a dozen priests across the country have been arrested on molestation charges, said the Rev. Tom Economus, who leads an organization of clergy sexual-abuse victims called the Linkup, which met in Washington just before the bishops' conference.

The Dallas verdict "clearly revealed the worst was not over," said the Rev. Charles Curran, ethics professor at Southern Methodist University in Dallas and a former theologian at Catholic University in Washington. "The problem is still with us, and it's just not going to go away."

Father Economus and others say that the pedophilia crisis appeared to have peaked after Cardinal Joseph Bernardin of Chicago was accused of molestation in 1993. When his accuser, Steven Cook, later withdrew his lawsuit, saying his memory might be faulty, the clergy sexual-abuse crisis dropped from the top of the church's agenda.

For a few years, victims didn't come forward as often, and the media wrote less about the problem.

That has changed since the summer. Now, say Linkup members, dioceses may be coming to the bargaining table because of the Dallas verdict.

One Linkup member said he pushed a news article about the Dallas case across a table when a church representative balked at paying for his therapy and compensation. Today he has a pending settlement, though it includes a gag order that bars the man from identifying himself, his abuser or the diocese.

Another of those who attended the Linkup convention was the Rev. Gary Hayes, a Roman Catholic priest from Kentucky who was himself molested by a cleric while growing up in New Jersey. The Dallas judgment, he said, "energized me."

He said the judgment could end church secrecy on the abuse issue. "I pray every day for it," Father Hayes said, "several times a day."

Father Economus, who is active in a breakaway Catholic movement, said every one of the 193 American dioceses has been home to a priest/molester, if only for a short time. The church has paid out at least $ 650 million in claims, and the number could climb to $ 1 billion, he said.

Catholic officials say the claim amount is lower, although they also acknowledge that they haven't kept track of the figure.

The size of the Dallas judgment angers many bishops.

"You're making the people pay for something they didn't do," said Archbishop Patrick Flores of San Antonio. "We have no control. The priests are adults."

Bishop Edmond Carmody of Tyler had a more measured response.

"The judgment was abnormally high," he said. But even if his diocese faced such a jury verdict, he said, "we can survive all that. Dioceses recover. To make sure there are no victims is our major concern."

Archbishop Rembert Weakland of Milwaukee said most bishops believe the major molesters have been rooted out of the priesthood.

Now, he said, bishops are trying to figure out how to care for victims and what to do with accused priests.

Asked whether he was concerned about the potential financial costs of abuse lawsuits, Archbishop Weakland said, "Certainly if I were in Dallas, I would be frightened."

Bishop Joseph Delaney of Fort Worth said he doubted another pedophilia scandal would emerge in his diocese, which dealt with a highly publicized case three years ago.

"We're beyond all of it," he said. "This thing in Dallas is anomalous. Whatever happens now is taken care of as soon as it's discovered."

He said he is annoyed that the issue is still so prominent.

"You pick up the paper every day and see stories that never seem to let the issue die, and that's disturbing," he said.

But Bishop John Kinney of St. Cloud, Minn., who heads a committee studying clergy sexual abuse, disagreed with people who blame the media for investigating abuse cases.

"The story has to be told," he said, and some litigation has been necessary. "Unfortunately, sometimes that had to happen because nobody could get attention."

One part of the story is the verdict's effect on Bishop Charles Grahmann of Dallas.

The bishop arrived last week at the Washington conference after a trip to Rome. Between sessions, other bishops touched him on the arm or clapped him on the back.

"There seems to be sympathy for the suffering of Bishop Grahmann, for the terrible stress and strain it's put on him and the whole church of Dallas," said Bishop Joseph Fiorenza of Galveston-Houston, who is also vice president of the group.

During the conference, Bishop Grahmann wouldn't publicly discuss the effect of the Kos verdict - either nationally or locally - because, he said, the case is still in litigation.

He said he was eager to talk once the case is settled. "I've got a lot to say about it," he said.

On Tuesday afternoon, Bishop Grahmann nearly fainted and was admitted to a Washington hospital for observation. He said he was still tired from his trip to Rome and had skipped two meals. A few bishops wondered whether the stress of dealing with the Kos verdict was getting to him.

Asked about their concern, Bishop Grahmann acknowledged that the lawsuit has added extra pressure to his job.

"Every year, I live under immense pressure," he said. "Anything else adds more. So, yes, I wasn't able to take my vacation this year and get away to relax. But I don't run from my responsibilities."

The bishop was released from the hospital Wednesday and returned to the conference.

Around the edge of the proceedings, which officially focused on rather mundane church matters, was the question of how to deal with the jury's judgment in Dallas - and how to deal with clergy sexual abuse.

"I think the church is in a painful awakening to some realities," said Janet Smith, a well-known philosophy professor at the University of Dallas. "In the past, they tried to act with the going wisdom, which was that if a priest made a good confession, he could be trusted to change his ways. And now we realize it's a deeper problem."

She said she hopes that in the future the Dallas Diocese will be more careful about its response to molestation complaints and about its screening procedures.

Meanwhile, Catholics in Dallas are left to deal with the judgment.

"Financially, it could be disastrous," Dr. Smith said. "I have no doubt that someone who is abused by an official in the church deserves compensation. I don't complain about my money being used for that. Fairness requires it. But the size of this amount is incredible. The damage that it can do will be heartbreaking."

In the end, parishioners across the country will continue to become more polarized, said Leon Suprenant, vice president of a traditionalist laity group called Catholics United for the Faith, based in Ohio.

Liberal Catholics, he said, contend that the church's demand that priests be celibate is one cause of sexual abuse.

Conservatives, he said, blame the crisis on the church's allowing homosexuals into the priesthood.

"Both are wrong," Mr. Suprenant said.

He's not sure what the cause is - except maybe plain sin.

For people seeking a spiritual life, the pedophilia crisis is tragic, he said.

"What does this do to the person who may be looking for the truth, for Christ, and concludes, It can't be here?' " Mr. Suprenant wondered. "From Galileo to the Holocaust to pedophilia - it's just one more hurdle for the church. . . . The whole cumulative effect makes our witness that much more difficult."

Staff writer Brooks Egerton contributed to this report.

[Photo Captions: 1. Michael Sheehan . . . Santa Fe archbishop says the Dallas judgment was excessive. 2. Charles Grahmann . . . bishop says that the lawsuit has added extra pressure to his job. 3. Anthony Pilla . . . bishop talked about pedophilia during his annual presidential address.]

Diocese Tries to Protect Properties
Large Kos Case Judgment Leads to Legal Maneuver

By Brooks Egerton
Dallas Morning News
November 27, 1997

The Catholic Diocese of Dallas, seeking to protect assets from a huge molestation-conspiracy judgment, has filed legal documents suggesting that it doesn't own parish properties.

The papers put in writing what the diocese previously argued in court: that Bishop Charles V. Grahmann, though listed in public records as the properties' owner, holds them for the parishes' benefit and in name only.

The formality of filing the documents with county clerks could open the door to removing the bishop as trustee, said Mike Daniel, a high-profile lawyer active in his White Rock-area parish.

Mr. Daniel questioned the assertion that the diocese doesn't own parish property. But, "if true, this represents a fundamental change in the laity-clergy relationship," he said Wednesday.

Civil law allows for removal of trustees if a court deems them insolvent or incompetent. Bishop Grahmann, Mr. Daniel said, is both - "he got insolvent as a direct result of incompetence" in handling the case of suspended priest Rudolph "Rudy" Kos.

"I'm feeling newly empowered," Mr. Daniel said. "He should resign as trustee."

Diocese lawyer Thomas Kurth said he doubted that would happen and rejected Mr. Daniel's analysis as "a leap of logic."

"I don't think there's grounds for removal of the bishop as nominee-holder" of the properties, Mr. Kurth said. "That is a hell of a jump."

Chet Hinshaw, an attorney representing most of the pastors in the nine-county diocese, acknowledged that Mr. Daniel could pursue a civil claim against the bishop, but "he could have done that before."

Windle Turley, one of the plaintiffs' attorneys in the molestation case, said the filings represent an illegal effort by diocese officials to transfer assets and "avoid paying what they owe."

Mr. Kurth portrayed the county-clerk filings as "simply a memorialization of an existing fact." They were made at pastors' request to put plaintiffs' attorneys on notice that the properties were off limits, Mr. Hinshaw said.

Jurors concluded July 24 that top church officials failed to protect 11 altar boys from Mr. Kos and fraudulently concealed evidence of suspicious behavior.

The filings are "fraudulent concealment manifest," Mr. Turley said. "We're going to get to the bottom of this."

He and the other plaintiffs' attorney, Sylvia Demarest, said after the trial that the diocese made little effort to settle the case beforehand. Diocese officials initially responded with accusations of unreasonably high demands; they have since backed away from that position and blamed their insurers for not being willing to pay.

The diocese has said it cannot pay the $ 119.6 million Kos judgment without insurance help and could be forced into bankruptcy if plaintiffs try to collect.

Collecting remains impossible for now because state District Judge Anne Ashby still hasn't signed off on the jury's verdict.

Both sides have said they don't understand the four-month delay.

Neither Judge Ashby nor Ms. Demarest could be reached for comment Wednesday.

Meanwhile, efforts to reach a post-trial settlement continue, as does litigation between the diocese and its insurers. The companies say their policies don't cover the jury's finding of intentional misconduct.

Mr. Daniel suggested that Bishop Grahmann's resignation as property trustee would help bring an end to all the litigation.

"I think the parishioners can broker a better deal with the plaintiffs than the bishop will," he said.

Speaking in Washington recently to a gathering of clergy-abuse victims from around the country, Ms. Demarest acknowledged that she and Mr. Turley might never collect the entire judgment. She also said she didn't want to disturb basic church and school operations.

In an interview with The Dallas Morning News last month, she attacked the notion that the diocese doesn't own parish properties.

Church officials, she said, "are attempting to create the fiction that somehow the parishes and schools are not under the direct jurisdiction, control and ownership of the bishop of Dallas."

The documents submitted to county clerks in recent days are called "stipulations of beneficial interest." A typical filing states that Bishop Grahmann holds the property title "for the benefit of Christ the King parish."

The parish is defined as "the owner and holder of all equitable and beneficial interest and title in the property."

That doesn't mean, Mr. Kurth said, that parishes can make major financial decisions without the bishop's permission or appoint their own pastors. They remain "subject to all of the provisions of canon law of the Roman Catholic Church and the laws of the state of Texas," the filings state.


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