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.
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
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