COUNTERCLAIM Now come the Plaintiffs (by counterclaim) by counsel(s), and counterclaim as follows: Nature of the Action 1.

This Counterclaim seeks permanent injunctive relief restraining RCB and its agents(Defendant in counterclaim) from interfering with rights of Plaintiffs (in Counterclaim)to continue Prayer Vigil in the church and all collateral activities, seeks a preliminary and permanent injunction to restrain RCB and/or its agents from removing the steeple of the church or any other structure or thing of the Historical Building and seeks an accounting of all Mater Dolorosa donations and applications of same over the past 13 years including the Future of Hope campaign capital fundraiser which raised over $425,000 from Mater Dolorosa Church. 2. The Defendant(RCB)has attempted to interfere with rights of the Plaintiff parishioners (paid members) to continue a 24/7 Prayer Vigil and other religious free and peaceful exercises at church by coercion and intimidation while Plaintiffs continue appeals in Rome. 3. The Defendant(RCB) has threatened to remove the steeple of the Mater Dolorosa Church wrongfully and presented exaggerated projected church repairs on several occasions as a pretext to eject Plaintiffs from their church causing them great emotional distress and disturbance. 4. The Plaintiffs say the Defendant(RCB) and its agents have unreasonably withheld critical financial information relating to the church closing/merger regarding the Mater Dolorosa Parish receipts and expenditures over the past 13 years.

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The Parties 5. The Plaintiffs, in this counterclaim, are all of the Defendants listed as Defendants in the original complaint of RCB, Victor Anop, Peter Stasz, et als whose listed addresses are as recited in the original complaint, and re-incorporated herein by this reference. 6. The Plaintiffs are paid Parishioners of the Mater Dolorosa Church subjected to a franchise association with RCB apparently sanctioned by the Roman Catholic Church in Rome, Italy, the originators of the Catholic Faith. 7. The Defendant in this counterclaim is the Plaintiff in the original complaint, RCB,a Mass. Corporation Sole and its predecessor agents or assigns, whose current Chief Executive Officer is: Bishop Timothy A. McDonnell with an address of 65 Elliot Street, Springfield, Hampden County, Massachusetts. 8. The RCB, (and its agents, including, but not Limited to Pastor Alex Cymerman) is the organization claiming the corporate power to exercise full dominion, supervision,and control over the Mater Dolorosa Church. 9. The Defendant RCB has submitted itself to the jurisdiction of this civil court by virtue of the filing of the complaint in this action. Facts Pastoral Planning 10. Plaintiffs state, on information and belief, that Defendants Pastoral Planning was simply a vehicle to close churches in the RCB franchise limiting the input of the grass root souls from the churches in the flawed process; the process essentially had a pre-determined outcome by the selected hierarchy of the church, and their appointees. -10-

11. As a result of this pre-determined process, the Plaintiffs say they were denied a fair & proper hearing by the Defendant RCB to defend the continuing existence of their religious pursuits at the Mater Dolorosa site; Plaintiffs allege that unfair pastoral planning process was the main reason for closing of Mater Dolorosa Church. Defendants Threats, Intimidation or coercion 12. Plaintiffs say, on information and belief, that Defendants attempted to threaten, intimidate or coerce them by hiring and dispatching security guards who initially came to the church unidentified on or after June 30, 2011,scared elderly parishioners constituting bullying, and took away property at the Church and signs while members prayed, and exercised religious freedom. 13. Plaintiffs say that the Defendants security guards chill the prayer activities of the Plaintiffs and they continue to threaten, intimidate or coerce Plaintiffs from exercising their rights to religion and association freely by the continued every-day surveillance, and confiscation of prayer signs. 14. Plaintiffs say that Defendant bringing an action against them for conducting a Prayer Vigil, while protecting their church, constitutes and consummates threatening, intimidation or coercion against Plaintiffs exercise of freedom of religion at their church. Defendants Building Safety Claims 15. Plaintiffs say, on information and belief, that Defendants have exaggerated,and misrepresented Historical Buildings condition based on incomplete engineering reports,and a false statement of a building inspectors role leading to a fraudulent initiative against Plaintiffs to justify taking down the church steeple; By color of civil law, RCB tries to evict Plaintiffs from their listed Historical Church Building and close it permanently. 16. Plaintiffs say, on information and belief, that the steeple of the church, and other building issues indicated by subjective Defendant vendors, are simple repair issues, and are not immediate or imminent safety concerns; RCB has misrepresented these issues as a reason for closing M.D. (See:Mitchell Reports(3)& Aff. of Neal B. Mitchell,Eng.)

Defendants Withheld Financial Data 17. Plaintiffs say they are dues paying members and contributors of the Mater Dolorosa Church, and some are contributors and volunteers for church activities including bazaars, bingo, parish and financial council, school committee, and church lectoring; Many have freely given time and specific gifts to the M.D.Church & its successor. 18. Plaintiffs, say on information and belief, that requests for complete financial information regarding their members donations, and disposition thereof, have been unreasonably withheld from them by Defendant and its agents. Plaintiffs further say that under Canon and civil law Defendants have a duty & obligation to provide such data to ensure that donations earmarked for an intended purpose have, in fact, been expended for that purpose. 19. Plaintiffs say, on information and belief, that there appears to be mismanagement of directed gifts to the building fund as simple repairs to the steeple, stairs and parts of the roof have not been done and there are no reports of targeted building funds being used for that purpose; yet the RCB cites steeple repair and a deficit alleged over $700,000 as reasons to close the church without giving financial statements regarding designated gifts. 20. Plaintiffs say, on information and belief, that annual financial statements were wrongfully not made available to them from the Mater Dolorosa Church agents as required by an order of the Bishop(RCB)as a fiduciary duty and responsibility of the RCB; the withholding of such data has harmed the Plaintiffs by not allowing them to discern if their designated gifts have been properly used.

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Causes of Action COUNT 1 Civil Rights Violations 21. The Plaintiffs re-alleges and incorporate by reference its previous allegations in this counterclaim. 22. The Defendant RCB is a Massachusetts Corporation Sole. 23. The Defendant RCB has carried on a pattern of threatening,intimidating or coercive activities against Plaintiffs, as previously described, which has deprived and attempted to deprive them of their constitutional right under the First Amendment of the U.S. Constitution and the Massachusetts Constitution (Part the First, Art.III)& G.L.c. 12, ss.11H & llI, to exercise their freedom of religion at their sacred Mater Dolorosa Church. COUNT II Fraud, Misrepresentation, Breach of Fiduciary Duty 24. The Plaintiffs re-alleges and incorporate by reference its previous allegations in this counterclaim. 25. Plaintiffs say, on information and belief, that the Defendant RCB has made false and misleading claims regarding the condition of the Mater Dolorosa Church and its steeple; its campaign to remove the steeple instead of repairing it with unaccounted designated building funds, is fraudulent and a breach of its fiduciary duty.

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COUNT III Breach of fiduciary Duty-Failure to Produce Financial Statements 26. The Plaintiffs re-allege and incorporate by reference its previous allegations in this counterclaim. 27. Plaintiff says, on information and belief, that the Defendant RCB and its agents wrongfully refuse to produce full and complete financial statements of the Mater Dolorosa Church to members which should include annual receipts and expenditures as ordered by the Bishop, a description of all designated gifts and past special capital fundraising efforts and their allocation; Defendant, and its agents, has breached its fiduciary duty and responsibility by first not publishing all such statements to the Plaintiff church members, and then refusing to produce the unpublished held records upon Plaintiffs request for such verification. Prayers for Relief WHEREFORE, Victor Anop, Peter Stasz, et als, Defendants in the complaint and Plaintiffs via counterclaim, request that this court grant the following relief: 1. That this court dismiss the complaint of RCB, with prejudice, and 2. That this court issue an injunction permanently enjoining and restraining RCB from coercing, intimidating or interfering with Defendants (in Complaint)right to Prayer Vigil, praying and other similar religious rights and activities, at Mater Dolorosa Church, and 3. After hearing, issue a preliminary injunction restraining and enjoining RCB from removing the Mater Dolorosa steeple or doing unnecessary repairs within and without the listed Mater Dolorosa Historical Building, and 4. After a trial on the merits issue a permanent injunction restraining and enjoining the full activities described in Prayer(3) above, and -14-

5. After hearing, issue an order mandating that RCB produce a full financial accounting, including designated gifts and their allocation, of the Mater Dolorosa Church from calendar year 1998 through and including 2011, and 6. Dismiss the action against Iwana Boruch(sic), a misnomer; dismiss the action against Helen Domurat for failure to serve process upon her, and 7. After hearings and trial, order such other relief as The court deems just, proper, and equitable. Defendants, under original complaint, request a jury trial on all issues allowing for same.

Respectfully submitted for Original Defendants, _____________________________ VICTOR M.ANOP,ESQ.:BBO#019880 103 Bridle Path Rd.Chicopee,Ma. Tel.(413) 536-4181 Date: October 24, 2011 _________________________ PETER STASZ,ESQ.BBO#47744 62 Richard Eger Dr.Holyoke Tel.(413) 532-1511

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CERTIFICATE I, Victor M. Anop, Esq. hereby certify that a true copy of the foregoing answers & counterclaim were delivered, in hand, at: The Offices of Atty. John Flanagan 67 Market Place Springfield, Massachusetts on this 25th Day of October in the year, 2011. Date: 10/25/11 ______________________ VICTOR M.ANOP, ESQUIRE

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