UNITED
STATES
BANKRUPTCY
COURT
W
ESTERN
DISTRICT
OF
NEW
YORK
I
n
e:
)
Case
No.
20-~]
T
he
Diocese
of
uffalo,
N.Y.,
)
Chapter 11
D
ebtor.
)
A
FFIDAVIT
OF
CHARLES
MENDOLERA
REGARDING
THED
IOCESE'S
ASSETS
AND
OPERATIONS
AND
IN
SUPPORT
OF
T
HE
CHAPTER
1
PETITION
AND
FIRST
DAY
PLEADINGS
S
TATE
OF
NEW
YORK
)
C
OUNTY
OF
RIE
)
s.:
C
harles
Mendolera,
eing duly
sworn,
eposes
and
states
as
follows:
1
.
I
am
he
Executive
irector
of
inancial
Administration
( Executive
irector")
or
T
he
Diocese
of
uffalo,
N.Y.
the
Diocese ).
T
have
worked
n
the
Diocese's
inance
departments
ince
2004.
Prior to
being
ppointed as
Executive
irector
in
Apri12019,
served as
the
Diocese's
C
ontroller
and
efore
that
as
irector
of
ccounting.
I
am
amiliar
with
the
assets,
iabilities
and
s
ources
of ncome
or
the
Diocese.
2
I
make
his
Affidavit
based
upon:
a)
my
ersonal
knowledge
of
ertain facts
stated
h
erein,
(b)
nformation supplied
to
me
y
others associated
with the
Diocese,
c)
my
eview
of
r
elevant
documents, nd
d)
pon
my
xperience
and knowledge
of
iocesan
perations. If
were
c
alled
to
testify,
I
would
estify
to
the
facts
as
et
forth
herein.
I
am
uthorized
by
he
Diocese
o
s
ubmit
his
Affidavit.
3
.
On
February
28,
2020
the
"Petition
Date"),
the
Diocese
will
file
a
voluntary
p
etition
under
chapter 11
of
itle
11
of
he
United
States
Code
(11 U.S.C.
§
101
et
seq.,
the
`
Bankruptc
.
~ )
ommencing
ts
chapter
11
reorganization
case
(this
Chapter
11
Case )
K
~.~~ycs~:~va
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Case 1-20-10322-CLB, Doc 7, Filed 02/28/20, Entered 02/28/20 07:54:17,Description: Main Document , Page 1 of 59
4.
Contemporaneously
with
the
petition,
the
Diocese
will
also
be
i
ling
a number of
m
otions
and
applications
seeking
various
types
of
elief
on
an
expedited
basis
(collectively
the
irst
Day
otions ).
The
irst
Day
otions
seek
elief
aimed
at
facilitating
a
smooth
ransition
i
nto
this
Chapter
11
Case,
ermitting the
Diocese
o
continue
ts
mission
by
maintaining
employee
c
ompensation,
maintaining
the
goodwill
and
morale
of
he
employees,
arishioners,
clerics
and
o
thers
who
rely
on
the
programs and
services
provided
by
the
Diocese
and
preserving
and
m
aintaining
the
property
available to
satisfy
the
Diocese's
reditors.
I
have
reviewed each
of
he
F
irst
Day
Motions
and
am
amiliar
with
their
contents.
I
respectfully
submit
hat
all
of
he
First
D
ay
Motions
re
vital
to
the
Diocese's
eorganization
efforts
and
expedited
approval
of
he
First
D
ay Motions
s
important
o
the
Diocese's
uccessful reorganization.
O
PERATIONS
5
.
The
Diocese,
through
its
central
administrative
offices
(a)
provides
operatioiz~cl
s
upport
o
the Catholic
parishes,
schools
and
ertain
other Catholic
entities
that
operate within the
t
erritory
of
the
Diocese (each,
an
Other
Catholic Entity
or
OCE );
(b)
onducts school
o
perations
through
which
it
provides
parish
schools with
financial
and
educational support;
(
)
rovides
comprehensive
isk
management
ervices to
the
OCEs;
d)
dministers
a
ay
pension
t
rust
and a
priest
pension
trust
(collectively,
the
Pension
Trusts") for the
benefit
of
certain
e
mployees and
priests
of
the
OCEs;
and
(e)
rovides
administrative
support
for
St.
Joseph
I
nvestment
Fund,
nc.
( SJIF )
a
.
Operational Support.
The
Diocese
provides
operational
and
functional
s
upport
to
the
OCEs
n
the
areas
of
inance, building
&properties,
legal,
human
resources,
2
3501438.2
Case 1-20-10322-CLB, Doc 7, Filed 02/28/20, Entered 02/28/20 07:54:17,Description: Main Document , Page 2 of 59
stewardship
and communications,
canonical
tribunal,
schools,
evangelization
and
catechesis,
p
astoral
services
and
clergy
services.
b
.
School
Opernrtions.
The
Diocese
provides
financial
support
to
Catholic
e
lementary
and
high
schools
operating within
the
territory
of
he
Diocese.
c
.
Risk
Management.
The
Diocese
maintains
and
manages
a
risk
m
anagement
program
for
itself
and a
large
number of
OCEs,
nclusive
of
property,
liability,
W
orkers'
Compensation,
hort-term
disability, etc.
The
Diocese
also
administers
a
medical
elf-
insurance
program
which
provides
coverage
to
employees
of
the
Diocese
and
certain
other
p
articipating
OCEs.
The
isk
management
nd
ealth
insurance
programs
re
more
ully
described
i
n
he
discussion
below
with
respect
to
the
Diocese's Self
-Insurance
Motion
defined
below).
d
.
Pension
Trusts.
The
Diocese
sponsors
and
dministers
a
riest's
retirement
p
lan,
and
contributes to
a
frozen
pension
plan
for
lay
employees, each
of
which
are
described
in
g
reater detail
in
connection with
he discussion
of
he
Diocese's
Wages
Motion
as
efined
below).
e
.
SJIF.
The
Diocese
provides
administrative
support
to
the
St.
Joseph
I
nvestment
Fund,
nc.
SJIF
was
incorporated
as
a
separate
not
-for-profit entity
in
2006.
The
p
urpose
of
SJIF
is
to
receive
funds
from
participants
(which
include
the
Diocese,
parishes
and
o
ther qualified
organizations)
that
are
pooled
and
collectively
invested.
All
funds
of
the
p
articipants
are separately
accounted
for
by
SJIF.
Aboard
of
irectors
oversees
he
operation
of
S
JIF
and
an
investment
committee
of
he
board
is
responsible
for
adopting
an
investment
policy
a
nd
reviewing performance.
The
Diocese
provides personnel
to
assist
SJIF
with accounting
and
a
dministrative functions.
3
-
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