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VonRosenberg v Lawrence

VonRosenberg v Lawrence

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Published by TheLivingChurchdocs
Bishop Charles vonRosenberg asks U.S. District Court to declare that he is bishop of the Diocese of South Carolina.
Bishop Charles vonRosenberg asks U.S. District Court to declare that he is bishop of the Diocese of South Carolina.

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Published by: TheLivingChurchdocs on Mar 05, 2013
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03/05/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF SOUTH CAROLINACHARLESTON DIVISION
The Right Reverend Charles G. vonRosenberg,individually and in his capacity as ProvisionalBishop of the Protestant Episcopal Church inthe Diocese of South Carolina,Plaintiff,v.The Right Reverend Mark J. Lawrence andJohn Does numbers 1-10, being fictitiousdefendants whose names presently areunknown to Plaintiff and will be added byamendment when ascertained,Defendants.
)))))) CIVIL ACTION NUMBER:))
 
)
___________________________
)))))))COMPLAINT
 The Right Reverend Charles G. vonRosenberg, for his Complaint against the RightReverend Mark J. Lawrence and others whose names are presently unknown, states as follows:1.
 
This action for declaratory and injunctive relief arises from Defendant BishopLawrence
’s
unauthorized use of certain marks, names, and symbols associated with TheProtestant Episcopal
Church in the Diocese of South Carolina (the “Diocese”)
and his falserepresentations of fact made through and in conjunction with those marks. The Diocese is a partof The Protestant Episcopal Church in the United States of America (
“T
he Episcopal Church
” or “TEC”
or
the “Church”
). Bishop Lawrence is a former Bishop of the Diocese. In November2012, Bishop Lawrence renounced his ordained ministry in The Episcopal Church; in December2012, he was removed as Bishop of the Diocese. Pursuant to procedures set forth in theConstitution and Canons of The Episcopal Church, Plaintiff Bishop vonRosenberg was elected toreplace Bishop Lawrence as the Bishop of the Diocese. Nevertheless, Bishop Lawrence
 
2continues to use the marks, names and symbols of the Diocese
(the “Diocese’s marks”)
whileclaiming that he remains the Bishop of the Diocese. In so doing, Bishop Lawrence falselysuggests to consumers of religious services and charitable donors that Bishop Lawrence is anEpiscopal Bishop, that he is affiliated with the Diocese, that he is the true Bishop andecclesiastical authority of the Diocese, and that the Diocese authorizes and sponsors hisactivities. Bishop Lawrence
’s unlawful use of the Diocese’s marks
and misrepresentations of fact
unlawfully trade on the Diocese’s goodwill and reputation accumulated over its 200
-yearhistory as a sub-unit of The Episcopal Church. And they damage Bishop vonRosenbergirreparably by interfering with his ability to carry out his pastoral mission, to communicate withthe followers of his faith, and to attract new followers and charitable contributions to theDiocese. Declaratory and injunctive relief is necessary to enable Bishop vonRosenberg to carryout his pastoral mission and to compel Bishop Lawrence to cease misleading consumers of religious services as to the nature of his activities.
PARTIES
 2.
 
Plaintiff the Right Reverend Charles G. vonRosenberg, an ordained bishop of TheEpiscopal Church, is the Provisional Bishop of the Diocese, an office to which he was electedand installed at a special meeting of the Convention of the Diocese on January 26, 2013.3.
 
As the Bishop of the Diocese, Bishop vonRosenberg is harmed by any use of the
Diocese’s marks
or misrepresentation of fact concerning the Diocese that confuses consumers of religious services and charitable donors.4.
 
Defendant The Right Reverend Mark J. Lawrence is a former Bishop of theDiocese. Bishop Lawrence is no longer a bishop in The Episcopal Church and is no longer amember of the ordained clergy of The Episcopal Church. Bishop Lawrence nonetheless
 
3continues to hold himself out as the Bishop of the Diocese
and to use the Diocese’s marks to
suggest that his statements are on behalf of the Diocese and made with its sponsorship andauthorization.5.
 
Upon information and belief, Defendants John Does are individuals who areconsciously engaged in the unauthorized
use of the Diocese’s marks in
a manner that is likely toconfuse consumers of religious services and charitable donors, but whose identity and numbersare presently unknown.
JURISDICTION AND VENUE
 6.
 
This is an action arising under the Trademark Act of 1946 as amended, 15 U.S.C.§§ 1051
et seq.
 
(the “Lanham Act”).
 7.
 
This Court has subject matter jurisdiction pursuant to 15 U.S.C. § 1121(a) and 28U.S.C. §§ 1331, 1338.8.
 
Personal jurisdiction is proper over Bishop Lawrence because he is domiciled inthe State of South Carolina and has transacted business in the State.9.
 
Venue is proper in this District and division pursuant to 28 U.S.C. § 1391(b) andLocal Civil Rule 3.01(A) because Bishop Lawrence resides within this District and division. Inaddition, a substantial part of the events giving rise to the claims occurred in this District anddivision, including, but not limited to, Bishop Lawrence
s wrongful conduct and the harm suchconduct has caused and will cause to Bishop vonRosenberg.

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