Commonwealth of MassachusettsHampden, ss. Superior Court DepartmentCivil Action No. 11-831
Roman Catholic Bishop of Springfield, A Corporation Sole,Plaintiff v.
ANSWER TO COMPLAINT
Victor Anop, Peter Stasz, Halina SulewskiHelen Domurat, Shirley Anop, Eva Boruch,Iwana Boruch, Friends of Mater DolorosaChurch, John Doe#1,John Doe#2, Mary Roe#1, Mary Roe#2, and other John Does and Mary Roes,Defendants Now come the Defendants, by counsel(s), and answer thecomplaint as follows:1.Defendants admit to action brought, but denythat there is a “continuing trespass” to Mater Dolorosa.2.Denied. Defendants are paid members and volunteers ofthe church, and continue a prayer vigil to protect theirreligious freedom (right to pray), and their chosen church.3. Defendants admit that Diocese is bringing an actionagainst them for relief, but deny that “RCB” is doing sofor anyone’s safety.4.Denied. This allegation is blatantly untrue.5. Denied. Defendant’s comprehensive engineering reportrefutes allegation.6.Denied. This is a speculative conclusion not based upon valid and certified engineering data.7. Denied.8.Denied. The building and steeple are sound structures.