Table A. Plaintiffs are the parties aligned with The Episcopal Church however named or styled

Transcription

1 Table A Plaintiffs are the parties aligned with The Episcopal Church however named or styled and in whatever capacity they appear as more fully described in Table A of Plaintiffs the Episcopal Parties July 15, 2014 Amended Petition, which is hereby incorporated by reference. For the Court s convenience, Plaintiffs are listed below: The Church The Local Episcopal Parties The Congregations The Episcopal Church Presiding Bishop Katharine Jefferts Schori The Rt. Rev. Rayford B. High, Jr. The Rt. Rev. C. Wallis Ohl Robert Hicks Floyd McKneely Shannon Shipp David Skelton Whit Smith The Rt. Rev. Edwin F. Gulick, Jr. Robert M. Bass The Rev. James Hazel Cherie Shipp The Rev. John Stanley Dr. Trace Worrell Margaret Mieuli Walt Cabe Anne T. Bass The Rev. Frederick Barber The Rev. Christopher Jambor The Rev. David Madison Kathleen Wells The Rev. Christopher Jambor and Stephanie Burk, individually and as representatives of All Saints Episcopal Church (Fort Worth) Cynthia Eichenberger as representative of All Saints Episcopal Church (Weatherford) Harold Parkey as representative of Christ the King Episcopal Church (Fort Worth) Bill McKay and Ian Moore as representatives of Episcopal Church of the Good Shepherd (Granbury) Ann Coleman as representative of Episcopal Church of the Good Shepherd (Wichita Falls) Constant Robert Marks, IV, and William Davis as representatives of St. Alban s Episcopal Church (Arlington) TABLE A - PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 1

2 Vernon Gotcher as representative of St. Stephen s Episcopal Church (Hurst) Sandra Shockley as representative of St. Mary s Episcopal Church (Hamilton) Sarah Walker as representative of Episcopal Church of the Holy Apostles (Fort Worth) Linda Johnson as representative of St. Anne s Episcopal Church (Fort Worth) Larry Hathaway individually and as representative of St. Lukein-the-Meadow Episcopal Church (Fort Worth) David Skelton as representative of St. Mary s Episcopal Church (Hillsboro) All Saints Episcopal Church (Fort Worth) All Saints Episcopal Church (Wichita Falls) All Saints Episcopal Church (Weatherford) Christ the King Episcopal Church (Fort Worth) Episcopal Church of the Good Shepherd (Granbury) St. Alban s Episcopal Church (Arlington) St. Simon of Cyrene Episcopal Church (Fort Worth) St. Stephen s Episcopal Church (Hurst) St. Mary s Episcopal Church (Hamilton) St. Anne s Episcopal Church (Fort Worth) St. Luke-in-the-Meadow Episcopal Church (Fort Worth) St. Mary s Episcopal Church (Hillsboro) Episcopal Church of the Ascension & St. Mark (Bridgeport) Episcopal Church of the Good Shepherd (Brownwood) Holy Comforter Episcopal Church (Cleburne) St. Elisabeth s Episcopal Church (Fort Worth) Holy Spirit Episcopal Church (Graham) Holy Trinity Episcopal Church (Eastland) Our Lady of the Lake Episcopal Church (Laguna Park) Trinity Episcopal Church (Dublin) Trinity Episcopal Church (Henrietta) Iglesia San Juan Apostol (Fort Worth) Iglesia San Miguel (Fort Worth) St. Anthony of Padua Episcopal Church (Alvarado) St. Alban s Episcopal Church (Hubbard) St. Andrew s Episcopal Church (Fort Worth) St. Andrew s Episcopal Church (Breckenridge) St. Andrew s Episcopal Church (Grand Prairie) St. Barnabas the Apostle Episcopal Church (Keller) St. Gregory s Episcopal Church (Mansfield) St. John s Episcopal Church (Fort Worth) St. John s Episcopal Church (Brownwood) St. John the Divine Episcopal Church (Burkburnett) St. Joseph s Episcopal Church (Grand Prairie) TABLE A - PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 2

3 St. Laurence s Episcopal Church (Southlake) St. Luke s Episcopal Church (Mineral Wells) St. Mark s Episcopal Church (Arlington) St. Matthew s Episcopal Church (Comanche) St. Michael s Episcopal Church (Richland Hills) St. Paul s Episcopal Church (Gainesville) St. Patrick s Episcopal Church (Bowie) St. Peter-by-the-Lake Episcopal Church (Graford) St. Peter and St. Paul Episcopal Church (Arlington) St. Phillip the Apostle Episcopal Church (Arlington) St. Thomas the Apostle Episcopal Church (Jacksboro) St. Timothy s Episcopal Church (Fort Worth) St. Vincent s Episcopal Church (Bedford) St. Stephen s Episcopal Church (Wichita Falls) Episcopal Church of the Holy Apostles (Fort Worth) Episcopal Church of the Good Shepherd (Wichita Falls) TABLE A - PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 3

4 Table B Defendants are the parties that left the Episcopal Church however named or styled and in whatever capacity they appear as those parties defined themselves in footnote 1 of Defendants Answer to Plaintiffs the Episcopal Parties July 15, 2014 Amended Petition 1 and as more fully described in Table B of Plaintiffs the Episcopal Parties July 15, 2014 Petition, which are hereby incorporated by reference. For the Court s convenience, Defendants are listed below: The Diocese The Corporation The Individual Defendants The Congregations Individual Defendants wrongfully holding themselves out as, and appearing as, The Episcopal Diocese of Fort Worth Individual Defendants wrongfully holding themselves out as, and appearing as, The Corporation of the Episcopal Diocese of Fort Worth Franklin Salazar Jo Ann Patton Walter Virden, III Rod Barber Chad The Rt. Rev. Jack Leo Iker Judy Mayo Julia Smead The Rev. Christopher Cantrell The Rev. Timothy Perkins The Rev. Ryan Reed The Rev. Thomas Hightower Individual Defendants wrongfully holding themselves out as, and appearing as, the following Congregations: ST. ANTHONY OF PADUA CHURCH (Alvarado) ST. ALBAN S CHURCH (Arlington) ST. MARK S CHURCH (Arlington) CHURCH OF ST. PETER AND ST. PAUL (Arlington) CHURCH OF ST. PHILIP THE APOSTLE (Arlington) ST. VINCENT S CATHEDRAL (Bedford) ST. PATRICK S CHURCH (Bowie) ST. ANDREW S CHURCH (Breckenridge) GOOD SHEPHERD CHURCH (Brownwood) ST. JOHN S CHURCH (Brownwood) CHURCH OF ST. JOHN THE DIVINE (Burkburnett) 1 Plaintiffs challenge and do not concede that Defendants can properly represent The Corporation of the Episcopal Diocese of Fort Worth or the Episcopal Diocese of Fort Worth or any of the Intervening Congregations. TABLE B - PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 1

5 HOLY COMFORTER CHURCH (Cleburne) ST. MATTHEW S CHURCH (Comanche) TRINITY CHURCH (Dublin) HOLY TRINITY CHURCH (Eastland) CHRIST THE KING CHURCH (Fort Worth) HOLY APOSTLES CHURCH (Fort Worth) IGLESIA SAN JUAN APOSTOL (Fort Worth) IGLESIA SAN MIGUEL (Fort Worth) ST. ANDREW S CHURCH (Fort Worth) ST. ANNE S CHURCH (Fort Worth) CHURCH OF ST. BARNABAS THE APOSTLE (Fort Worth) ST. JOHN S CHURCH (Fort Worth) ST. MICHAEL S CHURCH (Richland Hills) CHURCH OF ST. SIMON OF CYRENE (Fort Worth) ST. TIMOTHY S CHURCH (Fort Worth) ST. PAUL S CHURCH (Gainesville) GOOD SHEPHERD CHURCH (Granbury) CHURCH OF THE HOLY SPIRIT (Graham) ST. ANDREW S CHURCH (Grand Prairie) ST. JOSEPH S CHURCH (Grand Prairie) ST. LAURENCE S CHURCH (Southlake) ST. MARY S CHURCH (Hamilton) TRINITY CHURCH (Henrietta) ST. MARY S CHURCH (Hillsboro) ST. ALBAN S CHURCH (Hubbard) ST. STEPHEN S CHURCH (Hurst) CHURCH OF ST. THOMAS THE APOSTLE (Jacksboro) CHURCH OF OUR LADY OF THE LAKE (Laguna Park) ST. GREGORY S CHURCH (Mansfield) ST. LUKE S CHURCH (Mineral Wells) CHURCH OF ST. PETER BY THE LAKE (Graford) ALL SAINT S CHURCH (Weatherford) ALL SAINT S CHURCH (Wichita Falls) CHURCH OF THE GOOD SHEPHERD (Wichita Falls) CHURCH OF ST. FRANCIS OF ASSISI (Willow Park) CHURCH OF THE ASCENSION & ST. MARK (Bridgeport) TABLE B - PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 2

6 Table C EXHIBIT A INDEX TO SUPPLEMENTAL APPENDIX IN SUPPORT OF PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DESCRIPTION APPENDIX PAGE(S) Affidavit of The Rt. Rev. C. Wallis Ohl A1-10 TAB 1 Report of the Resolutions Committee, 27th Annual Convention (Nov , 2009) A11-22 TAB 2 Letters of Congratulations and Commendation to Episcopal Diocese of Fort Worth and Deputies and First Alternates to Diocesan Convention (Nov. 6 & 12, 2009) A23-25 TAB 3 Notice of Deposition of Priests and Deacons (Feb. 15, 2010) A26-27 EXHIBIT B TAB 1 TAB 2 EXHIBIT D TAB 1 Affidavit of The Rt. Rev. Edwin F. Gulick, Jr. A28-34 Amended and Restated Articles of Incorporation of Corporation of The Episcopal Diocese of Fort Worth (Apr. 14, 2009) Letter to the Hon. William T. McGee, Jr. from Kathleen Wells, Chancellor of The Episcopal Diocese of Fort Worth (Mar. 3, 2009) A35-39 A40-41 Second Affidavit of Mark Duffy A Constitution & Canons for the Government of the Protestant Episcopal Church in the United States of America Otherwise Known as The Episcopal Church (Church Publishing Inc., 2009) A TAB 2 Revised Title IV in effect until July 1, 2011 A TAB 3 Excerpts from The Episcopal Church Annual (Morehouse Church Resources, 2010) A TAB , 1786, and 1789 Journals of the General Convention, collected in Journals of the General Conventions of the Protestant Episcopal Church in the United States of America, from the Year 1784, to the Year 1814, Inclusive (Philadelphia: John Bioren, 1817) A TAB 5 Excerpts from The Book of Common Prayer (New York: The Church Hymnal Corporation, September A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 1

7 1979) TAB 6 Excerpts from the 1979 Journal of the General Convention A TAB 7 Excerpts from the 1868 Journal of the General Convention A TAB 8 Excerpts from the 1940 Journal of the General Convention A TAB 9 Excerpts from the 1904 Journal of the General Convention A TAB 10 Deposition of the Right Rev d Robert W. Duncan (Sept. 19, 2008) A415 TAB 11 Resolution adopted by the Executive Council at its meeting on June 11-14, 2007 A416 TAB 12 Excerpts from the 1838 Journal of the General Convention A TAB 13 Excerpts from the 1895 Journal of the General Convention A TAB 14 Excerpts from the 1895 Constitution of the Diocese of Dallas A TAB 15 Excerpts from the 1896 Canons of the Diocese of Dallas A TAB 16 Declaration of Conformity executed by the Rt. Rev. A. Donald Davies A540 TAB 17 Declaration of Conformity executed by the Rt. Rev. Clarence C. Pope A541 TAB 18 Declaration of Conformity executed by the Rt. Rev. Jack Leo Iker A542 TAB 19 Excerpts from The Proceedings of the Seventh Annual Convention of the Episcopal Diocese of Fort Worth (Oct. 6-7, 1989) A TAB 20 Excerpts from the Journal of the Special Diocesan Convention (Sep. 27, 2003) A TAB 21 Excerpts from the 1985, 1988, 1991, 1994, 1997, 2000, 2003, and 2006 Journals of the General Convention A TAB 22 Excerpts from the Journal of the Twelfth Annual Meeting of the Diocese of Fort Worth (Oct. 7-8, 1994) A TAB 23 Excerpts from the Journal of the Episcopal Diocese of Fort Worth 2006 A TAB 24 Excerpts from the Journal of the Tenth Annual Meeting of the Diocese of Fort Worth (Oct. 2-3, 1992) A TAB 25 Excerpts from The Order of Service for the Ordination and Consecration of the Reverend Jack Leo Iker to be a Bishop in the Church of God and Bishop Coadjutor of the Diocese of Forth Worth (Apr. 24, A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 2

8 1993) TAB 26 Excerpts from the Journal of the Thirteenth Annual Meeting of the Diocese of Fort Worth (Nov. 3-4, 1995) TAB 27 TAB 28 Renunciation of Ordained Ministry and Declaration of Removal and Release of the Rt. Rev. Jack Leo Iker (Dec. 5, 2008) Forms signed by Bishop Edwin F. Gulick, Jr. (Oct. 15, 2009) and the members of the Standing Committee of the Diocese of Fort Worth (Nov. 12, 2009) consenting to the ordination and consecration of Scott A Benhase as Bishop of the Diocese of Georgia A A608 A TAB 29 Excerpts from The Episcopal Church Annual (Morehouse Church Resources, 2009) A TAB 30 Excerpts from The Episcopal Church Annual (Morehouse-Barlow Co., 1984) A TAB 31 Excerpts from Proceedings of a Convention of the Clergy and Laity of the Protestant Episcopal Church in the State of Texas, 1849 A TAB 32 Excerpts from the 1850 Journal of the General Convention A TAB 33 Excerpts from the Journal of the Twenty-Fifth Annual Council of the Protestant Episcopal Church in the Diocese of Texas (May 28-30, 1874) A TAB 34 Excerpts from the 1874 Journal of the General Convention A TAB 35 EXHIBIT E Excerpts from the Journal of the Fourth Annual Convocation of the Protestant Episcopal Church in the Missionary District of Northern Texas (May 30 - June 1, 1878) A Affidavit of Gregory S. Straub A TAB 1 Excerpts from the 2009 Journal of the General Convention A TAB Annual Report of the Episcopal Diocese of Fort Worth A EXHIBIT F TAB 1 Affidavit of Kathleen Wells A Defendants Third Report from the Bishop and Standing Committee concerning The Anglican Province of the Southern Cone (Sept. 8, 2008) A889 TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 3

9 TAB 2 Defendants 10 Reasons Why Now Is the Time to Realign (Sept. 2008) A TAB 3 TAB 4 Report of the Committee on Constitution and Canons to the 26th Annual Convention of the Episcopal Diocese of Fort Worth Defendants Proposed Resolution for Admission to the Anglican Province of the Southern Cone (Nov. 2007) A TAB 5 Defendants As We Realign (Nov. 16, 2008) A TAB 6 Defendants Responses to Attempted Inhibition of the Bishop (Nov. 24, 2008) A TAB 7 Notice of Special Meeting of the Convention of the Episcopal Diocese of Fort Worth, Feb. 7, 2009 A900 TAB 8 USPTO Certificates of Registration of Diocesan Name and Seal (May 29, 2009) A TAB 9 Documents Showing Use of Diocesan Name and Seal A TAB 10 TAB 11 Excerpts from the Proceedings of the Twenty-Fifth Annual Convention of the Episcopal Diocese of Fort Worth, Nov Excerpts from the Journal of the Twenty-Seventh Annual Convention of the Episcopal Diocese of Fort Worth (Nov , 2009) and Special Meeting of Convention (Feb. 7, 2009) A895 A A TAB 12 Canon 17 regarding Corporation of the Episcopal Diocese of Fort Worth A EXHIBIT G Affidavit of Joseph A. Magliolo A TAB 1 Plaintiffs Second Amended Original Petition in Corp. of the Episcopal Diocese of Fort Worth v. McCauley (Feb. 15, 1995) TAB 2 TAB 3 TAB 4 Plaintiffs Motion for Summary Judgment, including Affidavits of Bishop Jack Iker and Reverend Canon Billie Boyd, filed in Corp. of the Episcopal Diocese of Fort Worth v. McCauley (Dec. 8, 1993) Plaintiffs Second Supplemental Evidence in Support of Their Motion for Summary Judgment, including Affidavits of Reverend Canon Billie Boyd and The Reverend Canon Charles A. Hough, III, filed in Corp. of the Episcopal Diocese of Fort Worth v. McCauley (Feb. 11, 1994) Affidavit of The Rt. Rev. William C. Wantland, filed in Corp. of the Episcopal Diocese of Fort Worth v. McCauley (July 29, 1994) A A A A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 4

10 TAB 5 TAB 6 TAB 7 TAB 8 TAB 9 TAB 10 EXHIBIT H TAB 1 Brief of Amici Curiae Rt. Rev. Jack Leo Iker, Bishop of the Episcopal Diocese of Fort Worth, and Rt. Rev. Robert Duncan, Bishop of the Episcopal Diocese of Pittsburgh, filed in Dixon v. Edwards (Jan. 8, 2002) Affidavit of R. Donald Davies in Support of Plaintiffs Original Petition, filed in The Episcopal Diocese of Dallas v. Mattox Articles of Amendment to the Articles of Incorporation of Corporation of the Episcopal Diocese of Fort Worth (Filed Nov. 4, 1987) Articles of Amendment to the Articles of Incorporation of Corporation of the Episcopal Diocese of Fort Worth (Filed Nov. 27, 1991) Amended and Restated Articles of Incorporation of Corporation of the Episcopal Diocese of Fort Worth (Filed Apr. 14, 2009) Defendants Certificate of Correction to Amended and Restated Articles of Incorporation of Corporation of the Episcopal Diocese of Fort Worth (filed Apr. 21, 2009) A A A A A A Affidavit of The Rev. Canon Charles K. Robertson A Letter to The Most Rev d Katharine Jefferts Schori from the Rt. Rev d Dorsey F. Henderson, Jr. (Jan. 9, 2008), and regarding the Rt. Rev d John-David Schofield (with attachment) A TAB 2 Deposition of the Right Rev d John-David M. Schofield (Mar. 12, 2008) A1249 TAB 3 TAB 4 TAB 5 EXHIBIT I Letter to The Most Rev d Katharine Jefferts Schori from the Rt. Rev d Dorsey F. Henderson, Jr. (Dec. 17, 2007), and regarding the Rt. Rev d Robert W. Duncan (with attachment) Forms signed by Bishop Wallis C. Ohl (June 14, 2010 & July 17, 2010) consenting to the ordination and consecration of bishops Letter to six former members of the Standing Committee of the Diocese of Fort Worth from The Most Rev d Katharine Jefferts Schori (Dec. 15, 2008) A A1262 A Supplemental Affidavit of Mark Duffy A TAB 1 Excerpts from the 1979 Journal of the General Convention A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 5

11 EXHIBIT J Second Supplemental Affidavit of Mark Duffy A TAB General Convention Resolution Number 1982-A010 to Amend Constitution Article V.1 A1272 TAB 2 EXHIBIT K 1982 General Convention Resolution Number 1982-B018 to Ratify the Division of the Diocese of Dallas Into Two Jurisdictions A1273 November 29, 2010 Supplemental Affidavit of Kathleen Wells A TAB Constitution and Canons of the Episcopal Diocese of Fort Worth A EXHIBIT L January 5, 2011 Affidavit of The Rt. Rev. C. Wallis Ohl A TAB 1 Excerpts from The Directory of the Episcopal Diocese of Fort Worth (REDACTED) (Dec. 2010) A TAB 2 Notice of Deposition of Priests and Deacons (Feb. 15, 2010) A TAB 3 Notices of Inhibition for The Rev. Joel Hampton and The Rev. Jon C. Jenkins (Nov. 10, 2010) A EXHIBIT M TAB 1 EXHIBIT N EXHIBIT O TAB 1 TAB 2 January 4, 2011 Affidavit of Cherie Shipp A Plaintiffs Amended & Restated Bylaws of the Corporation of the Episcopal Diocese of Fort Worth (Apr. 4, 2009) Intervening Defendants Congregations Supplemental Response to Plaintiffs Requests for Disclosure Certified Copies of Deeds to Local Church Property Deed for Camp Crucis Property to Charles Avery Mason, as Bishop of the Protestant Episcopal Church, for the Diocese of Dallas (Jan. 20, 1948) Deed for Camp Crucis Property to A. Donald Davies, Bishop of the Diocese of Dallas of the Episcopal Church in the United States of America A A A A TAB 3 Deed for Alemeda St. Property to All Saints Episcopal School A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 6

12 TAB 4 Deed for Alemeda St. Property to Episcopal Diocese of Fort Worth A TAB 5 Deed for Alemeda St. Property from Diocese to Corporation A TAB 6 EXHIBIT P Deed for St. Mary s (Hillsboro) Property to Alexander C. Garrett, as Bishop of the Protestant Episcopal Church, for the Missionary District of Northern Texas A March 21, 2011 Affidavit of the Rt. Rev. C. Wallis Ohl A TAB 1 List and Status of Congregations of the Episcopal Diocese of Fort Worth A TAB 2 Pastoral Letter from The Rt. Rev. C. Wallis Ohl to The Episcopal Diocese of Fort Worth (Jan. 23, 2011) EXHIBIT Q EXHIBIT R EXHIBIT S EXHIBIT T EXHIBIT U A Affidavit of Constant Roberts Marks IV for St. Alban s Episcopal Church (Arlington) A Affidavit of Sandra Shockley for St. Mary s Episcopal Church (Hamilton) A Affidavit of Owanah Anderson for All Saints Episcopal Church (Wichita Falls) A Affidavit of Phil McClendon for All Saints Episcopal Church (Weatherford) A Affidavit of Janice Schattman for Christ the King Episcopal Church (Fort Worth) A TAB 13 Google Search Results for Defendant Christ the King Episcopal Church Fort Worth A EXHIBIT V EXHIBIT W EXHIBIT X Affidavit of Ian Moore for Episcopal Church of the Good Shepherd (Granbury) A Affidavit of David Skelton, M.D. for St. Mary s Episcopal Church (Hillsboro) A Affidavit of Rebecca McKneely for St. Stephen s Episcopal Church (Hurst) A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 7

13 EXHIBIT Y EXHIBIT Z EXHIBIT AA Affidavit of Ann B. Coleman for Episcopal Church of the Good Shepherd (Wichita Falls) A Affidavit of Linda Johnson for St. Anne s Episcopal Church (Fort Worth) A Affidavit of Kyle D. Young A TAB 1 Certified copy of Deed of Trust to Jude Funding, Inc. A TAB 2 Certified copy of St. Barnabas (Fort Worth/Southlake) Deed of Trust A TAB 3 Certified copies of St. Alban s (Arlington) Deeds of Trust A TAB 4 Certified copies of Oil and Gas Leases A TAB 5 Copies of Oil and Gas Leases produced by Defendants A TAB 6 Deed Records for Episcopal Property produced by Defendants A TAB 7 Additional Deed Records for Episcopal Property A TAB 8 Local Episcopal Parties First Set of Interrogatories to Defendants, First Requests for Production of Documents, and Exhibits (Feb. 8, 2011) A TAB 9 Defendants Response to Local Episcopal Parties First Set of Interrogatories (Feb. 17, 2011) A TAB 10 Documents naming Diocesan Funds, as produced by Defendants A TAB 11 Account statements and Summaries of Accounts, as produced by Defendants A TAB 12 Plaintiff the Rt. Rev. C. Wallis Ohl s First Request for Production of Documents to Southern Cone Congregations (Nov. 9, 2010) A TAB 13 Report from the meeting of ACNA Chancellors A2284 EXHIBIT BB EXHIBIT CC Affidavit of John H. Meeks for St. Simon of Cyrene Episcopal Church (Fort Worth) A September 8, 2009 Affidavit of The Rt. Rev. Edwin F. Gulick, Jr. A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 8

14 EXHIBIT DD Affidavit of The Rev. Dr. Marion Roy ( Sam ) McClain A TAB Newsletter Article, Diocesan Seal Rich in Heritage A2295 TAB 2 Excerpts from The Episcopal Church Annual (1984) A TAB 3 Cover Pages from Diocesan Journals for 1990, A EXHIBIT EE EXHIBIT FF Affidavit of The Rt. Rev. Edwin F. Gulick, Jr. A Affidavit of Kathleen Wells A TAB 1 Letter from Geoffrey Mantooth to Walter Cabe (Jan. 22, 2009) A TAB 2 Excerpts from Defendants Website (Nov. 23, 2010) A TAB 3 Online Search Results (Nov. 23, 2010) A EXHIBIT GG Affidavit of Elinor Normand A TAB 1 (redacted) (Nov. 1, 2010) A2329 EXHIBIT HH Affidavit of Jimmy Wayne Morrison (Oct. 15, 2014) A The Episcopal Church, Church Pension Group Summary A2332 EXHIBIT II Affidavit of Mark J. Duffy (Oct. 15, 2014) A Excerpts from the Minutes of Executive Council of The Episcopal Church (Oct , 1923) A Excerpts from the Minutes of Executive Council of The Episcopal Church (Oct. 9-10, 1929) A Report generated by The Resolves of Council (a digital archive of the votes taken by Executive Council of The A2341 Episcopal Church for the period 1976 to 2011) containing an excerpt from the Executive Council Minutes (Feb. 9-11, 1983) 4 Report generated by The Resolves of Council containing an excerpt from the Minutes of the Executive Council A2342 TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 9

15 of The Episcopal Church (Nov , 1985) 5 Excerpts of Records of the United Thank Offering, Awarded Grants (1986) A Report generated by The Resolves of Council containing an excerpt from the Minutes of the Executive Council A2346 of The Episcopal Church (Nov , 1988) 7 Report generated by The Resolves of Council containing an excerpt from the Minutes of the Executive Council A2347 of The Episcopal Church (Feb. 28 through Mar. 3, 1989) 8 Excerpts from the Episcopal Church United Thank Offering Grants (1991) A Excerpts of Records of the Episcopal Church United Thank Offering Grants (1994) A Report generated by The Resolves of Council containing an excerpt from the Minutes of the Executive Council A2352 of The Episcopal Church (June 12-15, 1995) 11 Excerpts from the United Thank Offering Grants (1996) A Excerpts from the Records of the United Thank Offering (1996) A Report generated by The Resolves of Council containing an excerpt from the Minutes of the Executive Council A2360 of The Episcopal Church (Jan , 1997) 14 Report generated by The Resolves of Council containing an excerpt from the Minutes of the Executive Council A2361 of The Episcopal Church (June 11-14, 2004) 15 Excerpts of Records of the Episcopal Church United Thank Offering, Grants ( ) A Excerpts from the Annual Report of the Presiding Bishop's Fund for World Relief (1991) A Excerpts from the Annual Report of the Presiding Bishop's Fund for World Relief (1996) A Excerpts from the Records of the Presiding Bishop's Fund for World Relief ( ) A Excerpts from the records of the Episcopal Church Building Fund, which was formerly known as the American A Church Building Fund 20 Excerpts from the List of Grants, from the Presiding Bishop's Fund for World Relief ( ) A Excerpts from the List of Grants from the Presiding Bishop's Fund for World Relief (through 6/94) A EXHIBIT JJ Affidavit of Dr. Joshua C. Tate (Oct. 16, 2014) A Index and deed from Weatherford Public Library A Deeds from County Clerk s Office of Tarrant County, Texas A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 10

16 3 Excerpts of History of St. Andrew s Episcopal Church, Centennial Year, 1975 A Excerpts of The History of the Episcopal Church in Fort Worth: Controversy Amongst Tradition A Excerpts of St. Andrew s Call, St. Andrew s Parish, Fort Worth, Texas A Excerpts of documents from the archives of the Wise County Historical Society A The Form and Order of the Dedication of All Saints Episcopal Church, Fort Worth, Texas, The Diocese of Dallas (1954) A Fundraising booklet for All Saints Episcopal Church of Fort Worth, Texas A History and newspaper articles regarding Christ the King Episcopal Church of Fort Worth, Texas A Booklet for St. Luke s-in-the-meadow Episcopal Church of Fort Worth, Texas (Oct. 17, 1971) A Newspaper articles regarding St. Martin-in-the-Fields Episcopal Church of Keller, Texas A The History of St. Michael s Episcopal Church (Aug. 1977) A The History of St. Vincent s Episcopal Church (1978) A A history of St. Luke s in the Meadow Episcopal Church of Fort Worth, Texas (Dec. 2, 1982) A Historical information regarding The Texas Churchman, a periodical published by St. Andrew s Episcopal Church of Fort Worth, Texas A The Texas Churchman, Vol. 1, No. 4 (Nov. 1984) A Excerpts from The Episcopal Church in Texas, , From Its Foundation to the Division of the Diocese (1963) A Excerpts from The Episcopal Handbook (2008) A Excerpts from Saints and Symbols of All Saints A EXHIBIT KK TAB 1 Second Affidavit of Joseph A. Magliolo (regarding Defendants Documents) A Letter from The Rev. Canon Charles A. Hough, III and N. Michael Kensel to The Rev. Steven Pope (Aug. 13, 2007) A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 11

17 TAB 2 Letter from N. Michael Kensel to Marshall M. Searcy regarding St. Mary's Mission (Hillsboro) and St. A Lawrence Parish (Southlake) (Feb. 12, 2008) TAB 3 Letter from N. Michael Kensel to Tarrant Appraisal District (Nov. 2, 2007) A TAB 4 IRS Exemption Letter (Aug. 13, 1984) A TAB 5 Letter from Internal Revenue Service to Episcopal Diocese of Fort Worth (Oct. 22, 2003) A2633 TAB 6 Article of Conformity for St. John the Divine (Burkburnett) (Oct. 10, 1961) A2634 TAB 7 Letter from C. Avery Mason to John G. Morgan regarding Church of St. John the Divine (Oct. 12, A ) TAB 8 History of St. Andrew s Episcopal Church, Fort Worth, Texas (1997) A TAB 9 Annual Meeting Report, Saint John's Episcopal Church (Fort Worth) (Jan. 21, 2001) A TAB 10 St. John's Episcopal Church Vestry Meeting Minutes (Dec. 14, 2000) A TAB 11 Dedication Service, St. John's Episcopal Church (Mission) (July 12, 1925) A TAB 12 Charter of All Saints' Episcopal Church of Wichita Falls (Mar. 23, 1956) A TAB 13 Minutes of Organization Meeting of The Church of the Good Shepherd Parish, Brownwood, Texas A (Jan. 6, 1956) TAB 14 Charter of the Protestant Episcopal Church of the Good Shepherd of Brownwood, Texas (June 20, A ) TAB 15 Article of Conformity (Brownwood, Texas) A TAB 16 Report of "Protestant Episcopal Church of the Good Shepherd of Brownwood" to Texas Secretary of A State (Oct. 21, 1985) TAB 17 Letter from C. Avery Mason, Bishop, to all Rectors, Wardens, and Vestries, Diocese of Dallas, with A attached report of the Committee on Corporations TAB 18 Vestry Minutes, The Church of the Good Shepherd (Oct. 8, 2006) A TAB 19 Petition for an Organized Mission, St. Joseph's Episcopal Church (Grand Prairie) A TAB 20 The Journal of the Episcopal Diocese of Fort Worth (2007) A TAB 21 The Executive Council Minutes for the meeting held on Nov. 29, 2007 A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 12

18 TAB 22 The Journal of the Episcopal Diocese of Fort Worth (2008) A TAB 23 Funds Administered by the Finance Committee of the Episcopal Diocese of Fort Worth, Financial A Statements for the year ended Dec. 31, 2000 together with Auditor's Report TAB 24 Audited Financial Statements and Other Financial Information for Episcopal Diocese of Fort Worth A (Dec. 31, 1987) TAB 25 Standing Committee Minutes A TAB 26 Standing Committee Minutes A TAB 27 Standing Committee Minutes A TAB 28 Standing Committee Minutes A TAB 29 Bylaws of Corporation of the Episcopal Diocese of Fort Worth (Nov. 12, 1991) A TAB 30 from Paula Obermueller to Bishop's Committee of St. Barnabas the Apostle (Fort Worth) (Oct. A , 2007) TAB 31 Policy and Procedure for the Sale, Purchase and Encumbrance of Real Property Within the Episcopal A Diocese of Fort Worth TAB 32 Parish Bylaws, St. Mark's Episcopal Church (Arlington) (June 18, 2000) A TAB 33 Article of Conformity, St. Mark's Episcopal Church A3494 TAB 34 Letter from The Rt. Rev. Jack Leo Iker, Bishop of Fort Worth, to the Rector, Wardens, and Vestry of A The Episcopal Church of the Good Shepherd, Granbury, Texas (Mar. 15, 2002) TAB 35 Letter from The Most Rev. Katharine Jefferts Schori to Jack Iker (Nov. 2007) A TAB 36 Vestry Materials, Episcopal Church of St. Peter & St. Paul (Mar. 15, 2008) A TAB 37 Episcopal Diocese of Fort Worth Policies on Ethics and Integrity in Ministry (May 2006) A TAB 38 Notice of Voluntary Renunciation of Ordained Ministry by William H. Risinger, Jr. from The Rt. Rev. Jack L. Iker to Presiding Bishop, et al. (June 18, 2007) TAB 39 An Appeal to the Archbishop of Canterbury by the Bishops of Central Florida, Dallas, Fort Worth, Pittsburgh, San Joaquin, South Carolina, and Springfield (July 20, 2006) TAB 40 Letter from Co-trustee of the Joe and Jessie Crump Fund to St. Anne's Episcopal Church (Feb. 22, 1980) A3532 A A3539 TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 13

19 TAB 41 St. Anne's Episcopal Church, Written Resolution regarding "Saint Anne's Episcopal Church A owment Fund" (Jan. 14, 2001) TAB 42 Loan Circular, American Church Building Fund Commission A TAB 43 Letter from American Church Building Fund Commission to Mr. Charles F. Moser regarding loan for A3550 St. Anne's Church (Dec. 9, 1963) TAB 44 St. Anne s Episcopal Church, Declaration of Intention to Become an Organized Mission (Dec. 11, A ) TAB 45 Article of Conformity, Members of St. Anne's Mission A3552 TAB 46 Corporate By-Laws of St. Anne's Episcopal Church of Fort Worth (Mar. 14, 1965) A TAB 47 Article of Conformity, St. Anne's Mission, Fort Worth, Texas A3557 TAB 48 Articles of Incorporation of St. Anne's Episcopal Church of Fort Worth (Feb. 16, 1965) A TAB 49 Letter from Co-trustee of the Joe and Jessie Crump Fund to St. Anne's Episcopal Church (Fort Worth) A3562 (Feb. 22, 1980) TAB 50 Parish Bylaws, St. Gregory's Episcopal Church, Mansfield, Texas (May 13, 2002) A TAB 51 Article of Conformity, The Episcopal Church of Saint Gregory the Great Episcopal Church (Mansfield) A (Aug. 26, 1990) TAB 52 Letter from Texas American Bank to The Rev. Philip R. Cooke, St. Gregory's Episcopal Church A (Mansfield) regarding $150,000 Permanent Loan - Joe and Jessie Crump Fund (Jan. 17, 1985) TAB 53 The Episcopal Diocese of Fort Worth, Financial Guide, for use by Parishes, Missions, and Diocesan A Institutions (Aug. 1995) TAB 54 Diocesan Program Certificate from The Church Insurance Company of Vermont for St. Gregory s A3590 Episcopal Church (Mansfield) (Jan. 1, 2005) TAB 55 Article of Conformity, St. Francis of Assisi Episcopal Church (Willow Park) A TAB 56 History of St. Francis of Assisi Episcopal Church (Willow Park) A TAB 57 Letter from The Rev. William A. Komstedt, St. Francis of Assisi Episcopal Church (Willow Park) A3622 TAB 58 Petition for Mission Status, St. Francis Mission Station (Willow Park) (Nov. 9, 1982) A TAB 59 St. Francis of Assisi Episcopal Church (Willow Park), Annual Parish Meeting (Jan. 18, 2004) A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 14

20 TAB 60 Article of Conformity, St. Andrews Episcopal Church (Breckenridge) (Jan. 4, 1948) A3628 TAB 61 St. Andrew's Episcopal Church Policy Manual A TAB 62 Petition for Mission Status, Ascension and St. Mark's (Bridgeport) A3632 TAB 63 Ascension & St. Marks (Bridgeport) Sunday Bulletin (Mar. 7, 1965) A TAB 64 Brief History of St. Mark s Episcopal Church A3635 TAB 65 Bylaws, St. Mary's Episcopal Church (Hillsboro) (Sept. 14, 1980) A TAB 66 Letter from Our Lady of the Lake Episcopal Church to The Right Rev. A. Donald Davies (Aug. 31, A ) TAB 67 Texas Sales Tax Exemption Certificate, St. Vincent's Episcopal School A3652 TAB 68 School Manual, St. Vincent's Cathedral School A TAB 69 Standards of the Association, Southwestern Association of Episcopal Schools (May 2006) A TAB 70 St. Vincent's Episcopal Cathedral Church Financial Statements, Year ed Dec. 31, 2006 A TAB 71 St. Vincent's Episcopal Cathedral Church Financial Statements, Year ed Dec. 31, 2007 A TAB 72 Article of Conformity, The Church of the Good Shepherd (Brownwood) (Jan. 21, 1955) A TAB 73 Minutes of the Organization Meeting of the Parish of the Church of the Good Shepherd of the A Protestant Episcopal Church in the U.S.A. at Brownwood, Texas (Jan. 6, 1956) TAB 74 Article of Conformity (Ex. "C" to SC ) A TAB 75 By-Laws, Church of the Good Shepherd of Wichita Falls, a Texas Corporation A TAB 76 Vestry Oath of Office, St. Stephen's Episcopal Church A3753 TAB 77 Petition for Mission Status, St. Stephen (Oct. 21, 1966) A TAB 78 Authorization of Inclusion in National Church's Group Exemption, St. Stephen Episcopal Church (Apr. A , 1999) TAB 79 Vestry Bylaws, Saint Mark's Parish (Nov. 16, 1980) A TAB 80 Bylaws, Christ the King Episcopal Church (Unincorporated), Fort Worth, TX A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 15

21 TAB 81 Form Application for Recognition of Exemption Under Section 501(c)(3) of the Internal A Revenue Code for The Episcopal Diocese of Fort Worth (Nov. 9, 2007) TAB 82 Continued Application Materials (Nov. 9, 2007) A TAB 83 Supplemental Material IRS Required A TAB 84 March 8, 2006 Statement by Bishop Iker Separation At What Cost? A TAB 85 What Holds the Anglican Communion Together by Bishop Jack Iker (July 15, 2005) A TAB 86 Excerpts from Defendants Brief in Opposition of Respondents the Episcopal Diocese of Fort Worth, et A al. in The Episcopal Church v. The Episcopal Diocese of Fort Worth, No in The Supreme Court of the United States TAB 87 Episcopal News Service Archives ( A TAB 88 Excerpts from Defendant s Original Counterclaim and Intervenors Original Complaint in Philadelphia A Indemnity Ins. Co. v. The Episcopal Diocese of Fort Worth, No. 3:11-cv D in the United States District Court for the Northern District of Texas TAB 89 Excerpts from Appellants Reply Brief in The Episcopal Diocese of Fort Worth v. The Episcopal A Church, No in the Supreme Court of Texas TAB 90 Excerpts from Appellants Brief in The Episcopal Diocese of Fort Worth v. The Episcopal Church, No. A in the Supreme Court of Texas TAB 91 The Canons of The Episcopal Diocese of Fort Worth, Adopted in Conventions (Pls Dep. A Ex. 13) TAB 92 Warranty Deed (Pls Dep. Ex. 14) A TAB 93 Warranty Deed with Vendor s Lien (Pls Dep. Ex. 15) A TAB 94 Warranty Deed with Vendor s Lien (Pls Dep. Ex. 16) A TAB 95 Warranty Deed with Vendor s Lien (Pls Dep. Ex. 17) A TAB 96 General Warranty Deed (Pls Dep. Ex. 18) A TAB 97 Warranty Deed with Vendor s Lien (Pls Dep. Ex. 19) A TAB 98 Excerpts from Reporter s Record (Mar. 31, 2011 Hearing) A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 16

22 TAB 99 Excerpts from Reporter s Record (Apr. 28, 2011 Hearing) A TAB 100 Excerpts from Oral and Videotaped Deposition of the Defendant Appearing as Episcopal Diocese of A Fort Worth by Its Designated Representative Jack Leo Iker (Sept. 9, 2014) TAB 101 Excerpts from Oral and Videotaped Deposition of the Defendant Appearing as Corporation of A Episcopal Diocese of Fort Worth by Its Designated Representative Walter Virden (Sept. 10, 2014) TAB 102 Excerpts from Oral and Videotaped Deposition of Christopher Chad (Sept. 11, 2014) A TAB 103 Excerpts from Transcript of the Testimony of Jane R. Parrott (May 10, 2011) A TAB 104 Excerpts from the Journal of the Tenth Annual Meeting of the Diocese of Fort Worth (Oct. 2-3, 1992) A TAB 105 Excerpts of the Fifteenth Annual Meeting of the Diocese of Fort Worth (1997) A TAB 106 Excerpts of the Ninth Annual Meeting of the Episcopal Diocese of Fort Worth (Oct. 4-5, 1991) A TAB 107 TAB 108 EXHIBIT LL EXHIBIT MM EXHIBIT NN EXHIBIT OO EXHIBIT PP TAB 1 Excerpts of the Proceedings of the Second Annual Convention of the Episcopal Diocese of Fort Worth A (Sept , 1984) Excerpts of the Proceedings of the Sixth Annual Convention of the Episcopal Diocese of Fort Worth A (Oct. 8, 1988) Expert Affidavit of Dr. Joshua C. Tate (Sept. 30, 2014) A Expert Affidavit of Professor Gerry W. Beyer (Oct. 10, 2014) A Affidavit of the Rt. Rev. John Clark Buchanan A Affidavit of David Booth Beers A4111 Letter from David Booth Beers to William McGee (Oct. 19, 2006) A Third Affidavit of Joseph A. Magliolo A Excerpts from the Digest of the Canons for the Government of the Protestant Episcopal Church in the United States of America, Together with the Constitution (1893) A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 17

23 EXHIBIT QQ EXHIBIT RR EXHIBIT SS EXHIBIT TT EXHIBIT UU Affidavit of Jennifer Anderson A Additional Deeds A Affidavit of Kathleen Wells A Affidavit of The Rt. Rev. Canon Waggoner A Affidavit of Ednice Baerga A Affidavit of Anne Michels A TABLE C PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 18

24 Table D Episcopal Property, the property, or the disputed property refers to (1) the real and personal property listed in the table below, and (2) any and all real or personal property, of any character or kind, type or description, including all bank accounts and financial assets, that were held by or for the benefit of The Episcopal Church, the Diocese, the Diocesan Corporation, the Fund for the owment of the Episcopate, any of the parishes or missions of the Diocese (including but not limited to the congregations listed in Table F), or any other constituent entity of the Diocese, as of November 15, 2008, as well as any property acquired using, or as a result of, other Episcopal Property in any way, including but not limited to income generated by selling, investing, or encumbering with debt, leases, or liens any Episcopal Property, and property purchased with Episcopal Property or with funds derived from Episcopal Property. Episcopal Property also includes any and all property that originated as Episcopal Property, including any and all Episcopal Property that Defendants have re-characterized, transferred to different accounts, placed under different names, transferred to new entities, or commingled with other property. This table is not intended to be an exhaustive list of Episcopal Property; Plaintiffs are unaware of the full extent of Episcopal Property because Defendants have controlled the records since at least Relief granted by this Court in this case applies to all Episcopal Property. For the use of the Church at: All Saints (Fort Worth) REIS File Property Description No Being a portion of Block 1, WESTERN CROSSROADS, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Volume , Page 99, Deed Records, Tarrant County, Texas and being more particularly described by metes and bounds found in Document No , Deed Records, Tarrant County, Texas. A4118 A4223 SAVE & EXCEPT: A acre portion out of Block 1, WESTERN CROSSROADS, SOLD OUT BY Land Rover, Ltd and conveyed to Triton Advertising, Ltd as TABLE D PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 1

25 For the use of the Church at: REIS No. File Property Description described by metes and bounds found in Volume 11095, Page 2016, Deed Records, Tarrant County, Texas. [9500 N. Normandale Street] Lots 1 & 2, Block 26, CHAMBERLIN ARLINGTON HEIGHTS FIRST FILING, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Volume 63, Page 21, Deed Records, Tarrant County, Texas. [5001 Dexter] The W 90' feet of Lot A, Block 25, a revision of lots 1 to 20 and 25 to 40, inclusive Block 25, of CHAMBERLIN ARLINGTON HEIGHTS, FIRST FILING, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Volume 1348, Page 305, Deed Records, Tarrant County, Texas. [4939 Dexter] The S 122' feet of Lots 21, 22, 23 and the S 122' feet of the W 15' feet of Lot 24, all in Block 15, of CHAMBERLIN ARLINGTON HEIGHTS, FIRST FILING, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Volume 63, Page 21, Deed Records, Tarrant County, Texas. [4936 Dexter] All of Block 14, CHAMBERLIN ARLINGTON HEIGHTS, FIRST FILING, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Volume 63, Page 21, Deed Records, Tarrant County, Texas. [5001 Crestline] Lot 3-R, Block 26, CHAMBERLIN ARLINGTON HEIGHTS, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Cabinet B, Slide 672, Plat Records, Tarrant County, Texas. [5005 Dexter] Lots 6, 7, 8, the West 15 feet of Lot 5 and the East 20 feet of Lot 9, Block 26, CHAMBERLIN ARLINGTON HEIGHTS FIRST FILING, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Volume 63, Page 21, Deed JA01079 JA01087 JA01093 JA01099 JA01106 JA01112 JA01086 JA01092 JA01098 JA01105 JA01111 JA01120 TABLE D PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 2

26 For the use of the Church at: REIS No. File Property Description Records, Tarrant County, Texas. [5003 Dexter] TRACT I: Being a acres acre tract or parcel of land situated in the HAYS COVINGTON SURVEY, Abstract No. 256, Tarrant County, Texas and being the same tract as conveyed to James J. Johnson, Trustee, by Deed recorded in Volume 7577, Page 1368, in the Tarrant County, Deed Records and being more particularly described by metes and bounds found in Volume 12569, Page 23, Deed Records, Tarrant County, Texas. TRACT II: Being a acre tract or parcel of land situated in the HAYS COVINGTON SURVEY, Abstract No. 256, Tarrant County, Texas and being a portion of a tract conveyed to Vernon Savings & Loan Association as Tract II by Deed Recorded in Volume 8644, Page 481, in Tarrant County, Texas and being more particularly described by metes and bounds found in Volume 12569, Page 23, Deed Records, Tarrant County, Texas. SAVE & EXCEPT: A acre tract of land sold out by All Saints Episcopal School of Fort Worth to the Episcopal Diocese of Fort Worth, by deed as recorded in Volume 13735, Page 295, Deed Records, Tarrant County, Texas. Said acres being platted into Lot 1, Block 1, ALL SAINTS EPISCOPAL SCHOOL ADDITION, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Cabinet A, Slide 4305, Plat Records, Tarrant County, Texas. Said acres being platted into Lot 2, Block 1, ALL SAINTS EPISCOPAL SCHOOL ADDITION, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Cabinet A, Slide 6032, Plat Records, Tarrant County, Texas. Both Lots 1 & 2, Block 1, of the ALL SAINTS EPISCOPAL SCHOOL ADDITION, are revised and replatted into Lot 1, Block 1R, ALL SAINTS EPISCOPAL SCHOOL ADDITION, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Cabinet A, Slide 6883, Plat Records, Tarrant County, Texas. Lot 1, Block 1R, ALL SAINTS EPISCOPAL SCHOOL ADDITION, is further revised and replatted into Lot 1R, Block 1R, ALL SAINTS EPISCOPAL SCHOOL JA01796 JA01837 TABLE D PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 3

27 For the use of the Church at: REIS No. File Property Description ADDITION, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the plat thereof recorded in Cabinet A, Slide 9411, Plat Records, Tarrant County, Texas. [9745 Saints Circle] All Saints (Weatherford) N/A N/A Property held by All Saints (Fort Worth) through a wholly owned corporation that contains the real estate known as All Saints Episcopal School. The following described lot, tract or parcel of land, towit:-- Situated in Weatherford, in Parker County, Texas, and being part of Lot Number Three (3) in block No. eight (8) of the original town of Weatherford, described as follows: Beginning at the North West corner of the tract of land deeded by G.A. Holland et al on June 1st, 1920 to J.J. Pflanz, said point being an iron pin set in ground on the south line of West Church Street 230 feet West of the North East corner of said block No. 9, same being the North East corner of a tract of land deeded by Preston Martin, et ux to Mrs. M. C. Foat, on January 17th, 1922, by deed recorded in Volume 119, at page 528, Deed Records Parker County, Texas, to which reference is made: Thence South with the east boundary line of said lot so conveyed by Preston Martin and wife to Mrs. M.C. Foat 150 feet a corner, same being the Southeast corner of said lot and the Southwest corner of said Pflanz lot, an iron pin set in ground. Thence East 15 feet a corner; Thence North 150 feet a corner, in S. B. line of West Church street; Thence West with same 15 feet to the beginning. It being the intention of this deed to convey and there is hereby conveyed a strip of land fifteen feet wide and running across the west end of the tract of land conveyed by G.A. Holland et al to the said J.J. Pflanz which said deed so conveying said land by the said G.A. Holland et al to the said J.J. Pflanz is recorded in Volume 117, at pages Deed Records, Parker County, Texas, to all which said deeds and records reference is here made for all purposes. N/A JA01074 N/A JA All that certain lot, tract or parcel of land lying and being situated in Parker County, Texas and being a part of Lot 4, Block No. 8, of the Original Town of Weatherford, in Parker County, Texas, described by metes and bounds as follows: BEGINNING at the Southeast comer of a lot heretofore said Minnie Messer by Charley Cockran, et al, dated 16th day of August, A.D., 1940, recorded in Volume 176, Page 46, Deed Records, Parker County, Texas, which are here referred to and made a part hereof, said beginning point on the North Boundary Line of West Oak Street; THENCE West with the North Boundary Line of West Oak Street, 55 feet 9 inches a corner in the center of the driveway; JA01121 JA01132 TABLE D PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 4

28 For the use of the Church at: REIS No. File Property Description THENCE North to the center of a garage and through the center of same, 75 feet to a corner; THENCE East 55 feet 9 inches to a corner; THENCE South 75 feet to the North Boundary Line of West Oak Street to a corner, same being the Place of Beginning. Being the same property described in a Deed dated January 5, 1946, from Minnie Messer, a widow to Mary L. Woolsey, of record in Volume 203, Page 348, Deed Records, Parker County, Texas All that certain lot, tract or parcel of land lying and being situated in Parker County, Texas, and being a part of Lot No. 4, in Block No. 8, of the Original Town of Weatherford, Parker County, Texas, described by metes and bounds as follows: BEGINNING at the Southwest corner of said Lot No. 4, in Block No. 8, which said point is at the confluence of the East boundary line of South Waco Street, and the North boundary line of West Oak Street; THENCE East with the South boundary line of said Lot No. 4, Block No. 8, and the North boundary line of West Oak Street 69 feet 3 inches, to a point for corner in the center of an automobile driveway; THENCE North to the center of a garage and through the center of same 75 feet to a point for corner; THENCE West 69 feet 3 inches to a point for corner in the East boundary line of South Waco Street; THENCE South 75 feet to the North boundary line of West Oak Street, the same being the Place of Beginning. JA01133 JA01142 N/A The West 65 feet of the South ½ of Lot 4, Block 8, Original Town of Weatherford, Parker County, Texas, commonly known as 133 S. Waco, Weatherford, Texas. A2224 A2224 All Saints (Wichita Falls) All that certain lot, tract or parcel of land lying and being situated in Wichita County, Texas, being a 6.0 acre tract of land out of Block No. 2 of the Irrigation Subdivision of John A. Scott Survey No. 7, Abstract No. 297, and the O.H.P. Davis Survey, Abstract No. 65, Wichita County, Texas, and described by metes and bounds as follows: Beginning at a point on the North right-of-way line of Farm-Market Highway No. 369 where the same intersects the West right-of-way line of the City Aquaduct for the Southeast corner of this tract, said point being 60.0 feet at right angles from the center line of said Highway and 25.0 feet at right angles from the center line of said Aquaduct, and from which point the Northwest corner of John A. Scott Survey No. 7 bears N W feet; THENCE in a Westerly direction with the North right-of-way line of Farm- Market Highway No. 369 and 60.0 feet at right angles from the center line of said Highway following a curve to the left with a radius of feet for a distance of feet to a ½ inch iron rod for the Southwest corner JA00873 JA00877 TABLE D PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT Page 5