here - Grace Presbytery
Transcription
here - Grace Presbytery
FILED DALLAS COUNTY 3/26/2014 5:34:31 PM GARY FITZSIMMONS DISTRICT CLERK CAUSE NO. DC-13-10605 HIGHLAND PARK PRESBYTERIAN CHURCH INC., Plaintiff/Counter-Defendant, v. GRACE PRESBYTERY, INC., Defendant/Counter-Plaintiff. § § § § § § § § § IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 298TH JUDICIAL DISTRICT AFFIDAVITS IN SUPPORT OF GRACE’S FIRST AMENDED MOTION FOR ISSUANCE OF LETTERS ROGATORY AND FORTHCOMING MOTION FOR SUMMARY JUDGMENT Defendant Grace Presbytery files the attached three affidavits and would respectfully show the Court as follows: 1. Highland Park Presbyterian Church, Inc. (“HPPC”) made nine decades of repeated promises to accept property only for the use and benefit of the Presbyterian Church (U.S.A.). Now, HPPC has conspired with a new entity – a corporation called “ECO: A Covenant Order of Evangelical Presbyterians” – to break those commitments and take the property to benefit the new entity. The attached affidavits demonstrate that HPPC’s nine decades of promises are enforceable under the most basic neutral principles of Texas law. 2. HPPC has no valid basis for its actions – only the apparent belief that, as one person put it to HPPC: “Fortunately, Highland Park is large enough and strong enough to pretty much ignore the denomination nationally. . . .” HPCNTRL000102 (emphasis added). And there is no question that HPPC knows how wrong its actions are: As one HPPC forebear put it, taking this property “makes a mockery of [its] officer[s’] vows to uphold the church.” HPPC02114. Or as one HPPC pastor observed, HPPC’s conduct taking this property was a “coup.” HPCNTRL000566. DEFENDANT’S AFFIDAVITS IN SUPPORT OF FIRST AMENDED MOTION FOR ISSUANCE LETTERS ROGATORY AND FORTHCOMING MOTION FOR SUMMARY JUDGMENT – PAGE 1 OF 3. The attached affidavits demonstrate that HPPC’s actions are unacceptable under basic neutral principles of Texas law1: Professor Gerry Beyer, Governor Preston E. Smith Regents Professor at Texas Tech School of Law and author of the most-read legal blog on trusts and estates law in the nation, demonstrates that HPPC holds its property under an express, irrevocable charitable trust in favor of Grace Presbytery based on its written, signed commitments in 1984. See pp. 5-17 (Exhibit 1). Professor Beyer further demonstrates that Grace Presbytery is entitled to a constructive trust over the property based on HPPC’s constructive fraud. See pp. 18-25 (Exhibit 2). Dr. Joshua C. Tate, professor of trusts and estates, property law, and legal history at the SMU Dedman School of Law and Co-Chair of the Uniform Acts for Trust and Estate Law Committee of the ABA, demonstrates that HPPC holds its Main Campus land under an express irrevocable trust in favor of Grace Presbytery. See pp. 26-199 (Exhibit 3). 4. HPPC brought this ill-advised lawsuit and has no valid basis to resist discovery into HPPC’s taking of property it swore to hold in trust. ECO is a witness and perhaps a knowing participant in these actionable claims. Deposition of ECO meets any elementary test “that disputes may be decided by what the facts reveal, not by what facts are concealed.” Brewer & Pritchard, P.C. v. Johnson, 167 S.W.3d 460, 467 (Tex.App.—Houston [14th Dist.] 2005, pet. denied). 5. Evidence to date demonstrates that ECO induced HPPC’s conduct with promises about property ownership. See http://eco-pres.org/structure/eco-polity/ (last visited March 26, 1 This dispute began before Texas adopted the “neutral principles” approach, see HPCNTRL000174, and so application of that doctrine rather than the deference doctrine is unconstitutional, see Jones v. Wolf, 443 U.S. 595, 606 n.4 (1979). Without waiving that point, HPPC’s conduct is wrong under basic neutral principles of law. DEFENDANT’S AFFIDAVITS IN SUPPORT OF FIRST AMENDED MOTION FOR ISSUANCE LETTERS ROGATORY AND FORTHCOMING MOTION FOR SUMMARY JUDGMENT – PAGE 2 OF 2014) (selling ability to “retain full ownership rights to [] property” as a “Distinctive Element[] of Our Polity”); HPCNTRL000122 (“ECO is a very attractive home . . . . There is no trust clause binding the control of property to the presbyteries. . . . I trust you can see why our Session has made the recommendation it has.”); HPCNTRL001489 (urging complicity with ECO for “[a]bility to own and control our property, doesn’t make sense that we don’t own our own property”). 6. Evidence to date further suggests that ECO was collaborating with HPPC to induce and carry out these breaches. HPCNTRL002831 (Agenda for October 14, 2013 HPPC Session Meeting) (“[A]pplication to ECO will not be filed until after the congregational vote. Representatives of ECO nevertheless need to interview the Session this Monday in order for the application to be processed quickly by ECO if it is, in fact, filed.”); cf. HPPC’s Corrected Reply in Support of Emergency Mot. to Extend TRO, at 3 (Doc. #15) (N.D. Tex. Civ. Action No. 3:13-CV-3813) (representing to Federal Court on September 23, 2013 that purpose of injunction was to maintain the “status quo that has been in place for the past 87 years” (emphasis in original)). 7. ECO’s deposition and documents will confirm or refute HPPC’s claims in the lawsuit it brought. They will show what HPPC truly knew, thought, and did. They will show when HPPC began conspiring with ECO despite making ongoing representations to Grace and the PCUSA. And they will confirm or mitigate ECO’s role in these actionable claims. 8. Grace also files these affidavits in support of its forthcoming Motion for Summary Judgment, to be filed after additional discovery is completed. DEFENDANT’S AFFIDAVITS IN SUPPORT OF FIRST AMENDED MOTION FOR ISSUANCE LETTERS ROGATORY AND FORTHCOMING MOTION FOR SUMMARY JUDGMENT – PAGE 3 OF Respectfully submitted, /s/ Daniel L. Tobey William D. Sims, Jr. Texas Bar No. 18429500 Thomas S. Leatherbury Texas Bar No. 12095275 Daniel L. Tobey Texas Bar No. 24048842 Robert P. Ritchie Texas Bar. No. 24079213 VINSON & ELKINS L.L.P. 2001 Ross Avenue, Suite 3700 Dallas, Texas 75201 Tel: 214-220-7848 Fax: 214-999-7848 [email protected] [email protected] [email protected] [email protected] Attorneys for Defendant Grace Presbytery, Inc. CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 26th day of March, 2014, a true and correct copy of the foregoing document was served on the following parties in accordance with the Texas Rules of Civil Procedure: Kent C. Krause CRADDOCK DAVIS & KRAUSE LLP 3100 Monticello Avenue, Suite 550 Dallas, Texas 75250 and Lloyd J. Lunceford TAYLOR, PORTER, BROOKS, & PHILLIPS, L.L.P. 451 Florida St, 8th Floor Baton Rouge, Louisiana 70801 /s/ Daniel L. Tobey Daniel L. Tobey US 2371654 DEFENDANT’S AFFIDAVITS IN SUPPORT OF FIRST AMENDED MOTION FOR ISSUANCE LETTERS ROGATORY AND FORTHCOMING MOTION FOR SUMMARY JUDGMENT – PAGE 4 OF EXHIBIT 1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 5 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 6 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 7 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 8 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 9 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 10 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 11 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 12 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 13 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 14 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 15 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 16 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 17 EXHIBIT 2 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 18 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 19 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 20 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 21 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 22 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 23 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 24 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 25 EXHIBIT 3 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 26 CAUSE NO. DC-13-10605 HIGHLAND PARK PRESBYTERIAN CHURCH INC., § § IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS § Plaintiff, GRACE PRESBYTERY, INC., Defendant. § § § 298™ JUDICIAL DISTRICT § AFFIDAVIT OF DR. JOSHUA C. TATE STATE OF TEXAS ) ) COUNTY OF DALLAS ) Before me, the undersigned notary, on this day appeared Dr. Joshua C. Tate, known to me, who being by me duly sworn upon his oath deposed and stated as follows: 1. My name is Joshua C. Tate. I am over twenty-one (21) years ofage,of sound mind, and fully competent to make this Affidavit. I am a tenured faculty member at SMU Dedman School of Law, where, since 2005,1 have taught courses in trusts and estates, property law, and legal history. I have a J.D. from Yale Law School and a Ph.D. in History from Yale University. In the fall of 2012,1was a Lloyd M. Robbins Senior Research Fellow at the University of California at Berkeley. I currently serve as co-chair of the Uniform Acts for Trust and Estate Law Committee for the ABA Real Property, Trust and Estate Law Section, have chaired the Sutherland Prize Committee for the American Society for Legal History, and was recently appointed by the Selden Society as Honorary Secretary for the United States. I have published more than twenty-five AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 27 scholarly articles, essays, and book reviews, and have given invited presentations at numerous academic conferences, colloquia, and workshops both in the United States and abroad. I am the author of a student textbook entitled A Texas Companion for the Course in Wills, Trusts, and Estates, presently in its second edition. 2. The facts stated in this Affidavit are based on my personal knowledge, the History of the Highland Park Presbyterian Church published in 1967, the Bookof Church Order (1925) of the Presbyterian Church in the United States, Plaintiffs and Defendant's Appendices filed in this matter in regards to the temporary injunction proceedings, including the attached affidavits, and deeds relating to the property in question available in public records. The facts stated herein are true and correct to the best of my knowledge. If called as a witness, I would competently testify to such facts. 3. I have been asked by Vinson & Elkins LLP to review the factual background of the above-styled case to determine whether Plaintiff Highland Park Presbyterian Church Inc. ("HPPC" or "Plaintiff) holds its Main Campus land under an express irrevocable trust in favor of Grace Presbytery, Inc. ("GracePresbytery"), designated as the governing presbytery under the constitution of the Presbyterian Church (U.S.A.) ("PCUSA"). It is my opinion that Plaintiff does hold that property under an express irrevocable trust in favor of Grace Presbytery. 4. In December 1924, an association of the Presbyterian Church in the United States ("PCUS") announced a church building program including the promotion of a new church for Highland Park. See Exhibit 1 (Session Minutes of First Presbyterian Church of Dallas, 1923-1935), at 64-65. A Presbyterian Extension Board ("PEB")was formed in January 1926 to oversee the project, and was comprised of the pastor, one AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 2 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 28 elder, and one deacon from each of the PCUS churches in Dallas. See Exhibit 2 (Excerpts from History of the Highland Park Presbyterian Church, 1926-1967 (1967)), at 5 [hereinafter History, 1926-1967]. 5. In January 1926, George T. Reynolds, a member of the Executive Committee of Home Missions of PCUS ("PCUS Executive Committee"), and the PEB President, "called a little group of interested people together" to discuss the possibility of organizing a new PCUS church for Highland Park. In March1926,the group approached Dr. William Anderson, the Pastor of the First Presbyterian Church in Dallas, "to advise . . . on the proper form so as to conform to the Book of Church Order of The Presbyterian Church,U.S." Ex. 2 {History,1926-1967), at 5. 6. According to the PCUS's Book of Church Order in effect from 1925 to 1929, applicants for membership to a new church were required to respond affirmatively, "with uplifted hand," to the question, "Do you in reliance on God for strength, solemnly promise and covenant that you will walk together as an organized church, on the principles of the faith and order of the Presbyterian Church, and that you will study the purity and harmony of the whole body?" Exhibit 3 (Excerpts from Book of Church Order (1925)), 126(2). 7. The PCUS' s Book of Church Order also specified that, "[w]hen a particular church is incorporated, its meetings for the transaction of the business of the corporation will be provided for in its charter and by-laws, which must always be in accord with the Standards of the Presbyterian Church in the United States, and must not infringe upon the powers or duties of the Session or of the Board of Deacons." Ex. 3 {Book of Church Order (1925)),1157. AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 3 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 29 8. In addition, the PCUS's Book of Church Order (1925)provided that, "[i]f a church shall be dissolved by the Presbytery, or otherwise cease to exist, and no disposition has been made of its property, those who hold the title to the property shall deliver, convey, and transfer to the Presbytery of which the church was a member, or to the authorized agents of the Presbytery, all property of the church; and the receipt and acquittance of the Presbytery, or its proper representatives, shall be a full and complete discharge of all liabilities of such persons holding the property of the church." Ex. 3 {Book of Church Order (1925)), \ 158. 9. The first general meeting of persons interested in forming a Presbyterian Church in Highland Park was held on April 11,1926. Following a petition to Dallas Presbytery, permission was given on April 13,1926,to form the church. The Superintendent of Home Missions for the Presbytery, Dr. H.S. Springall, was "untiring" in helping the new church "get started." Ex. 2 {History,1926-1967),at 5. 10. In order to purchase the land for the church building, funds were sought from the PCUS Executive Committee. Following an appeal by George Reynolds, the PCUS Executive Committee agreed to contribute $7,500 toward the down payment on the property. Ex. 2 {History, 1926-1967), at 5-6. 11. On August 29, 1926, at a duly called meeting of the congregation in Highland Park, five individuals were named as "Trustees" for the purpose of buying land for the church building. These individuals were J.T. Coulson, John W. Carpenter, W.M. Whitenton, Henry R. Davis, and H.F. Boyd. Ex. 2 {History,1926-1967), 45.atOn September 27, 1926, T.C. Gilbert conveyed a 9.75 acre tract of land to the individuals appointed as Trustees. Exhibit 4 (Recorded Deed to Property, Main Campus). AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 4 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 30 12. On June 12, 1927, the congregation held a meeting "to consider the advisability of instructing the trustees to execute a bond and mortgage to the Executive Committee of Home Missions of the Presbyterian Church in the U.S. in the sum of $7,500," the purpose of the bond being to enable the church "to erect and possess a House of Worship." The bond required the Trustees to agree that "in the event this church should cease to be connected with the General Assembly of the Presbyterian Church in the United States," the money would be repaid to the Executive Committee. A motion to authorize the Trustees to execute the bond was unanimously approved. Exhibit 5 (Congregational Meeting Minutes, June 12,1927). 13. On January 31,1928, the Trustees formed a corporation named the Highland Park Presbyterian Church, the purpose for which was "the support of public worship to-wit: the maintenance of the Presbyterian Church." Exhibit 6 (HPPC Articles of Incorporation 1928). On March 11,1928, at a congregational meeting held pursuant to the PCUS's Book of Church Order, the Trustees were authorized to convey the land purchased in 1926 to the Corporation. Exhibit 7 (Congregational Meeting Minutes, Mar. 11, 1928). The Trustees did so on March 12,1928, by deed referencing the authorization at the March 11 meeting. Exhibit 8 (Deed Transferring to Corporation, 1928). 14. Because the land for the Highland Park church building was purchased prior to the adoption of the Texas Trust Act, the provisions of that Act do not apply. See Jackson v. Hernandez, 285 S.W.2d 184, 186 (Tex. 1956); Puente v. Mata, 346 S.W.2d 643, 645 (Tex. Civ. App.—San Antonio 1961, writ ref dn.r.e.). Prior to the adoption of the Texas Trust Act, a writing was not required for trusts of land. See Bamettv. Vincent, 7 S.W. 525, 526 (Tex. 1888); Ryan v. Lofton, 190 S.W. 752, 757 (Tex. Civ.App.—Fort AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 5 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 31 Worth 1916, writ dism'd). Under Texas law, "[n]o particular form of words is required to create a trust. If the intention of the parties is that the property shall be held and dealt with for the benefit of another, a court of equity will affix to it the character of a trust." Christopher v. Davis, 284 S.W. 253, 257 (Tex. Civ. App.—Dallas 1926, writ d). ref 15. Whether an express trust has been created depends on the intent of the parties. See Print v. Tate, 162 S.W. 2d 737, 739-41 (Tex. Civ. App.—Amarillo 1942, no writ). At the time that the HPPC property was acquired by the Trustees, a conveyance of land to certain individuals subject to an oral promise to hold the land in trust for another party would have created a valid and enforceable trust, vesting the equitable title in the other party. See Ryan, 190 S.W. at 757; Henderson v. Rushing, 105 S.W. 840, 841 (Tex. Civ. App.—Fort Worth 1907, writ refd); Clarence A. Guittard, Express Oral Trusts of Land in Texas, 21 Tex. L. Rev. 719 (1943). A trust must be construed according to the intention at the time of its creation. See Cutrer v. Cutrer, 334 S.W.2d599, 605 (Tex. Civ. App.—San Antonio 1960), ajf'd, 345 S.W.2d 513 (Tex. 1961); William Buchanan Found, v. Shepperd, 283 S.W.2d 325, 333 (Tex. Civ. App.—Texarkana 1955, writ granted w.r.m.). 16. In the present case, it is clear that the Trustees did not acquire the land purchased in 1926 for their own benefit, but rather for the purpose of transferring equitable title to a beneficiary so that a PCUS church could be built on the site. The minutes appointing the Trustees and authorizing the land purchase refer to the "church site property." Ex. 2 {History, 1926-1967), 45. at While the mere use of the term "Trustees" does not prove that a trust was created, see Brelsford v. Scheltz, 564 S.W.2d 404 (Tex. Civ. App.—Houston [1st Dist.] 1978, writ ref d n.r.e.), the intention of the AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 6 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 32 parties could only have been given effect through the creation of a trust. The question, then, is who held the equitable title to the land from 1926 onward. 17. As stated by the Texas Supreme Court in 1926, "[i]t is certain that an enforceable express trust may be created by one person agreeing to thereafter acquire title to land in his name for the benefit of others who agree to pay and do pay the consideration for the conveyance." Johnson v. Smith, 280 S.W. 158, 160 (Tex. 1926). Extrinsic evidence may be admitted for the purpose of charging the legal owner under a deed with a trust arising as a result of an agreement with another to pay the purchase price. See Jackson, 285 S.W.2d 191. at When considered together with the provisions in the PCUS's Book of Church Order quoted above, the official HPPC history makes clear that the Presbyterians who provided funds for the founding of the new church did so intending to benefit PCUS. Ex. 2 {History,1926-1967), at 5; Ex. 3 {Book ofChurch Order (1925)), ffll26(2), 157, 158. Moreover, the PCUS Executive Committee paid an important part of the consideration for the initial purchase of land by the Trustees. Ex. 2 {History, 1926-1967), at 6. 18. When the evidence shows that a valid trust had been created by oral agreement, subsequent acts by the parties are admissible to show how that agreement should be construed. See Graves v. Graves, 232 S.W. 543, 546 (Tex. Civ. App.— Amarillo 1921, writ refd). The 1928 HPPC Articles of Incorporation state that the purpose of acquiring the land was to benefit "the Presbyterian Church," which, at that time, could only have meant PCUS, to whose principles the HPPC charter members had sworn fealty. Exhibit 6 (HPPC Articles of Incorporation1928);Ex. 3 {Book of Church Order (1925)), If 26(2). PCUS and its Executive Committee were intimately involved at AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 7 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 33 all stages of the HPPC founding, not only granting permission for the new church, but also offering advice, encouragement, and support to the charter members. See Ex. 2 {History, 1926-1967), at 5. 19. In sum, the evidence demonstrates that the purchase of land in 1926 created an express trust in favor ofPCUS, not in favor of the local congregation or any competing denomination with which the congregation might later attempt to affiliate. Prior to the adoption of the Texas Trust Act, trusts were "considered to be irrevocable unless an expressed power of revocation was reserved in the terms of the trust." Isbell v. Williams, 705 S.W.2d 252, 255 (Tex. Civ. App.—Texarkana 1986, writ ref d n.r.e.). Since no power of revocation was reserved by the parties here, the subsequent transfer by the Trustees to the corporation could only have concerned the legal title to the land, not the equitable title that was irrevocably vested in PCUS. 20. PCUSA is the successor entity to PCUS, and Grace Presbytery is the regional embodiment of PCUSA. Exhibit 9 (Decl. of Michael Vaughn), at 2-4. Plaintiff, its Session, and its Board of Trustees therefore should be determined to hold the HPPC property under an irrevocable express trust in favor of Grace Presbytery. Further affiant sayeth not. Executed this seventh day of February, 2014. c /£ Joshua C. Tate, J.D., Ph.D. AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 8 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 34 SUBSCRIBED and SWORN TO before me on this / ^ d a y of February,2014. Notary Public - State of Texas My commission expires: /^a^ ' i V I C K I C .G R E E N Notary Public, State of Texas My Commission Expires I L ^ ._..__ J - U - l Jf_ 0 A- 20 ' 17 AFFIDAVIT OF DR. JOSHUA C. TATE - PAGE 9 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 35 CAUSE NO. DC-13–10605 HIGHLAND PARK PRESBYTERIAN IN THE DISTRICT COURT CHURCH INC. Plaintiff, v. DALLAS COUNTY, TEXAS GRACE PRESBYTERY, INC. Defendant 298TH JUDICIAL DISTRICT Exhibits Affidavit of Dr. Joshua C. Tate Ex# Description Bates Range 1 Session Minutes of First Presbyterian Church of Dallas, 1923-1935 Temporary Injunction, Defendant’s Appendix A111 – A119 2 Excerpts from History of the Highland Park Presbyterian Church, 1926-1967 GRA0080410 – 80507 3 Excerpts from Book of Church Order (1925) GRA0080400 – 80409 4 Recorded Deed to Property, Main Campus HPPC 03010 – 3011 5 Congregational Meeting Minutes, June 12, 1927 HPPC 03243 6 HPPC Articles of Incorporation 1928 HPPC 03085 – 3089 7 Congregational Meeting Minutes, March 11, 1928 HPPC 03238 – 3239 8 Deed Transferring to Corporation, 1928 HPPC 03014 – 3015 9 Declaration of Michael Vaughn Temporary Injunction, Defendant’s Appendix A11 – A23 US 2292604v.1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 36 EXHIBIT 1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 37 ¡ Case 3:l-3-cv-03813-B Document 27 Filed 09/30/1-3 Page L1-8 of 1.60 PagelD 583 ,ii3 fccq;iub;rr ðth, 19?zI ì'iondnY lok, ã. 'ilìre Sess lon 0'pri:ileiì t'i.f,h 'prÉttrr'elf r :r,?sent .t)T".;:i:t"i.1,lirro'r¡¡:son, jiotlcrl'¡,itoÏ, iììli; e::s ij.",rot,ioE; qÌ,ii.É.J)owe, ,,i..i., .IIo¡-ìp.e, S,lì".i|:cj.clcerriint.Baoon,lií.il "iTiffgins'.i!J .J.Voo1'hiso T¿ul. L{ifjl.p',i1;r'icÌr:rr'l'..t,".iìric:e,J.!.I'l:r"¡,'hChi.:nsCn,I.','i'.ìllrì'li.itrr'ii.iì" g ir i l c¡ o;t, " .i, . ì) l o vrni -9, S o ti . irIo,'l'iir il c$ r'i,i. lli " Th.o nU) o it. ,,e i;te:r Lj;:ci'n liï.!,,',.ri::onl.rlnd rr;B Co-1on:i-¿I 1liJ.1 .1.)t'egb:.¡'l;'¿rigtt 0i':ll.Tclr orclelet'l spz'czrcr on 'últG ttì ioolt**.,r'.t fol o,iI$, .l r'r .11 .f.'ec rrntlrer fl rl-9'¿+ " i.'.r ç l; or' .D:r :'/llt ; i,l.llfitl ers otl , " :,rnd i,iclrut:ora o:!l f r:c Of;flc.tl's.J .rllit .tc 'irìt Ii c-l irs t .!;'i:'¡,;ti .i by'tcrir,rn üL 0u:r .lJ;retiii'oil l-::, s n fil üi;itt.rc;lt, *::':i,'rs . .il+l- irt-t¿il : lrrqcti:irÊ' of l;ìrc öf:l'it.r*i'r:l o:[ "tlolnnjrrl iil^].1 i;ot'itrt¡t, olt iiresì'l;,rLcr:i.¿in. üiru,i:oir,hel"rl in t;he Ùht:-r'r.¡i ,rll(l- j. 'l;o sirtlr:l ;',;¿ut i'ttrs'votetl i:onrìr:i, ni.g'h | , .ì.'cct:iril:e r ttlb ,J'9!?,4,, 11; r¿1.1. 1 j.S or '''r1' f 6lrti: ;1Ou ¡io'r([ tir 1r:t Lei, Of :,ì"'i)F)i€lri,.'.tiort urlOr.)1Ê; lt,i;'t¡cr 'bOtr¡r- r.nql. i;rI'ü i,A OUf 'peOnJ-C !.n i:hCr tle',ily Ol'l'i'lrili:zetl Ohlr:rch. ltt ,l iO1ni: 'lii-nci ìie ,lri: r0n ,a:i:"i'Ùs:ttrI .Ílor- ti:r,r ?r:rcl 'hO bt-ry to t1'¡cl i.ås byt,l:r:y l.v $i :,'olr.Ï be.i.ovgd P;'tstor ',rro:'dl con0oI'nlilt'' ottt 1'¡OI'll ¡¡¡çì 'pr'ro1'r1e. fi'iranôt',rJ-'hrçJ.j'r t¡:r'l;BnCcrl to kec;Tl '"''lrc otrl Chtrrr:lr J.n Í.ts i)::*tlr;illlh¡',';v¡11-oir on''ib.L+fl u.iå iio 'ivo cùLt \tof Li ,Ìnçl i'v6vlr;r;t.'$ t,og'+tltu:r rrnti.J. 1;iri.s il"t;y ','t?rcn j.ffutlcJ itl;':ir;i.¡1 þ'rç r¡r! ¡tL¡ :inil r::pr')ü¿i lllrL: 0lruruì't ,,rÐ.rl .:3ol' 'iiÌit'l gÒ¡:lL ìrå' h¡IVÊ f Írli¡.:nc it.l. '¡t,:,:-t J,Ot;t û:rd.l hi'iyj.ïìP i.n 1[hn work r.rid;fJ. oLì!flc to s,r:i;¡; ¡'rôniiil anrl ilrr.li s.¿ I f sllllno:ú"Í. ììJC ùi:0 r":r¿r'i;r:j.r11 for l:|ç i'/o e.:rc iïr.;,tr¡:f'ttl f Or the i;'oc)(i ¡lj.l.l,'i:hri Iove, i;l:e f Íno fi:lllowsilÍ.p,ivhir:Ír j'ort hr':¡r¡9 1-l-.,¡ål;y$ r'::irtcnc1ciri;'¡ orlr ofJ'ict;rs ,;lÌ1C.1 ttì0lIìb í:¡r F,, 'ile ¡ 1'r:) c'r'ilto :flu1 a:nt1 lrall nevijt. 0$;igO tO lir:,ither , th,rt ycu çi';i'lf b f) ';1 ,t.ri. í; ii;Íully r,rnð r'::f .[le c i'-rl:'r:rine the t i't¡ ril l,ot'o 1;'n&zt ,,: j/e rìr, f illfn ITl) iresiiayç.He wu.s J:?ic ;f Í::c¡ 'f m:i,ni¡s1;¿rr:r,l to 11's itt Yt¡i.i r,$ strui.Eh'b Ílir,(-i',lrçpãrirú)cl t he jìr.r:icÜutchu"oil,',vlto ìr¿¿g btlrl n'iJ-r.'eir'rly' S t1C gc çj $ O1', OllT' ït11';¡ìti"ûè i]{t , i,il. :r f e'¿ utoirti'lç . i'-r-.li t'ì ï'r û¡ iinor,'¡ i'liLl. eonl: iût:.'il Lo bo, r.t, 0oii-send o oi¿r 0htrrglr . Oir.:: (ll¡u:'ci, cnl;ers i Ls f:ðiî I'C':J-,ìt i.r,lîg r:lÍ l;h .ioy *incl tì:r¡lnlr.s* rluj:' I i. ,r.ts , and ';IlJ t?.f o ¡ririÌ.ng i.n oLrr ire¿¡rÛt; ¡.n¡J i) T'¿ i o 1ll;r():l'.t r'i 1;f i:1,¡.tr;lê r)'?1ð g 'ul'e i"1¿ti;11 of ¡iTCt't.i.nl' i¡:¡ 1i;rr¡L:s¡ ¿li:tcl lrot¡"n d $, in 'r, l-r o lt.:.' I,o?d " A1l'l Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 38 Case 3:L3-cv-038L3-B Document 27 Filed 09/30/1-3 Page 1-19 of 160 PagelD 584 ß4 $ie thank Goil fôr"'tha X'irst Presï yt orlan Clruroh, for lts wonûsrful anct lovablo pastor a¡û its Go cl fearingand. falth- fuL menbere. In bohal"f of ths Sosslon end. Boarcl of Dea'oons' Yours fir. tþe tondorês$ bonds' of af fection, Ruling Signetl O1d.er D.E. Closland. Csrtifioate of qualifS.ostlon to thaoh orclered, iesuod to g.lr. nnre . ¡riAgços,'lrlrõ. ï[. 0.I'urga€o]1, Ufr-s. {.{!19qBy,l¡Ie.A.. D..Hod,ge, Mr.n{darn Davlä.sOn,Mr.Nat Valfiub,I,frs.1,{.8.IiJ.fbrd,lr'frS.H.W.[honnh1L1,Míss Nan MoCal.l anð lr¡lr.Qeo.MoCaJ.I. iÎLected. I\{r,ltr.C.I¡andru.m äs trey maÍr for this Churoh for ths Educatlonal rI/orlr,aocordlng to resoluù1on of ,Sreebytery. Commtttee on Dfspatch advertlsinS' roeom¡nentled that ws do not subs¿lriþe to Lt.heport actoptee wLttr thanks to tho 0ornmlttse. lr¡totion aåopterl that the Church Saturd.ay af telnoon p&pôr6. Lfir, S.6. trÍclladden eleoteü servloes bs aûvertlsod fn tlie tltreotor of Prebyterlan C].lnlc . letters g:ranted to trJIr.anô Mre.Ð.A,Careon,to Calvary Prebþytet'lan Church, Ssn ÍrranoÍeoo, CaL. l1an of orgaqtzation úor erçansion Broeirå,m approved with amenùment, às foLlows. i : ì .t the U. S. Plesbytertah Offt e.l-l minlsters anê offl,cors of t Dal"las, 'llðras, propose a program slon to neet thenresponstbtLttY I?resbyterlans ln Dal-l-ab ancl its 'e grs.m ior the tnmediate future Íncl-uctes tho foLLovufng: 1". fhe removal of the Colonl"al EllL Churqh totoa new ,' ióca[lon if the Brosent proporty can be so].d a-ôvantage. P. g. Tha promotion &, The The promotion land. ?ark. of a nov¡ ohuroh in southwest oak CIJ.ff. of 8, nsv/ ohurch for oek [au'rn and" IÏtgh- 1 r! 'I ì I I I 1 f I .i t ,a I : fosterlng 1n every plopor and. pra-ctios,l" røay-tho best lntorests of all of i;yrsse ¡rroBosodl ahurches, a1s0 the now church in no¡theaelb Dal'las recently organizeô by the Presbytery. 5. I'tthole-heari[eil oo-op€retion in evory way 150 the endL of makin8 the whoLo oauso in Dsl"las moet sffectlve both as to the organiøatlons no$¡ setabllsbeû and 8.1"1" approvedl A112 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 39 Case 3:L3-cv-0381-3-B Document 27 Filed 09/30/1-3 Page L20 of 160 PagelD 585 \it . ii I J il0iT c:llferyts t: ri rí llt . 'rlhf s ,ilx¡:a.nsloir ik'ogram is to, he os,rriod otrt e,s e dob¡'¿rLl to he i:oni.:rntlorts.l, offoi:b, aud j.s (lhulahelstr-¡el:bj.c¡iire,1;ectiit in ïe,Ll"as. It :is to bo the Éou-thorn Tresby'Éetrfair j,ve lJxeciut Coriunittee, conll:osocl u.nd,er i;ho clirrlc'L1oú. of a,n ì:]r the Í'rc¡:sÍovr of Ðea.con, â.pilofntecl ono ÏLd.nr ancl o:[ o].1úr oacjr of the co-Dl:'aro.tf.ng ohurchoe. tllre Chail'lrìû.ji of 1;lto Horne Iîísslon Üominitl;eo of lat]"s,e i'røs'byt'0f iilr e,lrct üiro !¿is'bor o:f el¿,otr nf 'Lho chnrchss glra.l"L olso be liteurl¡O:lg of Lho irl:reclut:î.vo Conrtrittoer, s.rl- offi.úio' llhe Di;oorrtirro Cornrnittoe eh&l1 bcj suthot':i.zed. 'i;o 'itrcorporat e :fÌor thc ¡ru.rposo ôf ce.rr;¡in¿1 otr"'b this iìx¡ioitsioT iltoä::arn. n,rd tiro Côrnmi.ttc.l siral"l" ccmi:ooc tÌ:o;f:Lt:st llo0,rtl r¡:f Diroó'ü r)rtJ o'! AT!:l C or¡ror'{e'ú1On or¡'loniø0cl. ll'lrre llìxoctr{¡:toi:r 0ornlnj.tteo shCI,l.l, r:r:.rrto;¡, tjre rleocl.,g of tho COmi"nrul.j-1;ieS l;O'i:o rl0Oui'rj.0d o,nt1 s¡hElLl" ost j.Ur¿tte t;þO flrr0È.111,' Tlo0cloCl a,i; onclt ¡:1.';.ce, o,nit illrel-.t üts.Ì10 o.:fr:Ll.l.::o¡rot:'i; o:i'c.l"l- o:i itc ¿,c'bj.oil¡¡ bcr LÌlo TI. lj. ).r'esìt;r1;tr;rj.cjl CJf:l' j'r:oïs .{esoc j"4,1;í'oir f or: i.'Ls; u¡:it:rov9'1 *li:ttl o.ircl to 'ùt're äono l,ii.ssioll Ournrrit'Lr¡c of i)¡,r.l.Ia o r-rQ$i)y"l¡c¡r-:!, '$& j.cl Clornnlj.'b'bçro o:t' oncro'L e o:ß all c a. t'i..:i.1;'L crn i':it;g.t emc¡nt ¡:Ia.trs l¡l:.al. l 'ila f:'ul:¡rishtlct 1;lrc clorll of liee:'li.On t¡f en,c'h of bhcl cltürcJlng Ìroff oi:a tho tnottl;1.ir.¡'4 cl:f tho II. $. .i-'rr'Jr:Jbybt''^'T:Î'n'11 O:t'f i'* ceT$3 jr$socis,1;io:lr, cl.'i;'¡¡hioh o:tfj.oj.ul. t¡.ct1on is 1;o ìrrl ta']:oil . rlrr ¡xlcl'r ¡rI.Ê.Ð$. l:t Í.s I I I i i ;' I I .i I r .,1 ñ !i ti il ,11 lj il ,:' ll rl a¡1reod "bhu,l; notü l,i1Ðslon iJork coiltetn¡rl-¡,toii. i.on O:f 0,ìrl,r i1¡';y¡ c;ì'nlClt O:t l:t:lsoíoir,'anil 'tho'plu,irs ofi uity llt¿j..l.cii.ir¡:;ll t.ir cotl:l.oetiOn 'hlro:'osìiùJ.1, rv j.tji, l11clt-A:Liril o?rru'aG'ücr o:f c;oustiltr.c:tIoir. C,ncì co,ç'Ls ' Il;':ocutJ-vo r¡Í"Lho ther e..¡11.,r'oval bo r:úìlnrj,ttod '';ô attcl, for corruni-1;too, llut i:P irot o'i:provcct by st:'clr 0ontrni'b"bo(r ' - s¿Ililo tnfll/ ìJê ¡¡róuocui;erI ì11,' Suôil chu.rc?l 3,il o.tt i.tltl tl¡,en.cloirt U¡lüor'* 'lry airy chUroh, Or ' tlro lrì Íi,11.:/ li, .l.ocrO.'l, l. li' t: 'üalcing. ü. S. Ironb¡¡i;orian 0ffi.ceÏs ;Lseocr:ì-e'biolt su¿1¡ients tirs.t o,Íl f:Joon o,$ thri ìlxocrr.tivo Cr.¡mmi.ttoc+ h¿r$ ì¡oerl so.ì.ectrrcl '"L'he a,nd ot'$tæ::i.zef,: proi:(ìQit s.'b onco Ito l/iû[c lts Í:ìu"],'rËJr o:f corrcli1. ft j.'.i í,i:s comìr11il i1;it¡s abrvo nro¡rtio:red a.::cl ¿1ot tlols bc ctê- *'i; oi.1cj0 0it strcb loc¿r.tione e,s :llg¡ ù LtIlôn " Ii; clovi.se ¿'Í; oilc o rl0I:ìË ile:f;i.ir:11'e scbolno o;ll :í. in.e,i:toln¡: llil:ot; e t epn of tþo proSl's.lï' cÇIiociå':[Iy e.s o ,snflgt s{; ioil ll'o . } * ?i. I1; conn:iðertlio eclvi saT¡ilit¡r p;¡i orn¡rl'o¡tj'11¡r p' C1"lu.i:'ch i.lxl¡oi.'¡si.on iïocr ata.v'Y to c¿r'r':r:y' out tho 't:l* oplti.cr-r'rr,: 'b e'¡' :'1. íl 'r" AlrS Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 40 Case 3:l-3-cv-03813-B Document 27 Filed 09/30/L3 Page L21, of L6O PagelD 66" panslon lrogram outlfnod abovo. 4. It irrgo on tho paetors of tho ohurahes the cl.esirablLtty of stroselng thfs ïvhoLe progra¡r beforo-osch oongrsgetion u¡tj.L tt fs sucoesg- fuily Launched. iütr. !11., N. lrlJtggins ol-ooted as El-d.er on Exeoutlvo ' Committee of the DxpansJ.on program anð nff. J. S. Pul11an tLeacoE.. 'Ihe foll"owing resolutlons were unanfmously atloptei[: Rov. [f. Freit- Galbraith, D. D. who has been ln baloveeð a¡rð. frullbfuL rel-al,ionshlp to thfs Churoh, aÊ its assoa1s.te mlnfstàr a.nrl Eoceoutlve Secretary, for the pa,st two yeåís, ha,s accopted the aaLl" of tbs }irst Llresbytorian ohurch of Denton to bocomo lts pastor. Ee haE tond.ersd" to us his reofgnation of his officlal relationshlp to us, wblclr has boea aoooBted. The Sesslon of thts 0hurch dsslrss, ln thls oonn6otion, ts exBress l1bs slncs?s attachnsnt to, anrl lovs for Dr. Gal"bra5"tlr, antl. to .ns.ke õuch €xBreÊslon a inatter of Bormansnt rec'or'c[. [hsrefore, l-t ls qesolvetl by the Seeslon of the Flrst ?reebytorlan Churoh of Dal-Ias:- L. Íhat Dr. Galbrallbh, tlrrough hto falthftrl, conÊocrated antl sfngLe-heartsfl mlnf try fn thÌs ohuroh has slgnalJ-y arid efflcfontly servedÌ our !ord. ín thls öongrogatton and. Ín the work at CoLonial HilL. Ee has r¡ron many to Chrlst through hf.s ylelcLod. responsivenÊss to tho Hol-y SBIrtt. IÍ€ ha.s doepened, 1n ma,ny, their frionftehlp with him of J.ong etanillng, rnalrlng also hosts of nsw friend.s, anrl oausÍr:g a].1- to rospect s,nil honor hfm. IIis exocutlle agefstsnce hae boen moËt substantieL ancl effectivo, and, more thaa all, his lttbors aê aotivo ¡ninfster and. pastoraL vfsftor among our pepplo at 0cjLonlal Htll. havo aiderl muoh ln the reestabllshnent anrl roorgs.nfzatton of that church. His work thero, wouLtL of Íteíetf , shovr that hs has had a ilofinate task in Dallas of vilia1 signffloanoo atlil lmportanco. 2, fhat whlle we shêll ooroLy nlss Dr. GaLbraith, vvs reoognÍøo that hfs fielil as Ba,stox of the $irst Churah at Denton, sncl his nocogss.ry aotivltlos as such, 'luhoro, anö in Öur church Courts ïullL bà n¡lil.er anù ftll"ler than they coultl bo u¡Íth ug ag assooiete ninistor ancl Exeoutlvo Seoretary. tfs oxperlonco anfl goodl jucl.gment tn 'bhs Churah Courts have aJ.ways given hÍm wiile anû vve].I merltecl lnf luence llhers. Vtro congra'tulate the benton chu¡ch and pry for it aad Dr. GaLbralth ín thelr now f,eLLorrushlp together, God.s richest bLassÍngs. W0 honor hfm snd" l-ove hlm. A114 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 41 Case 3:1-3-cv-038L3-B Document 27 Filed 09/30/L3 Page L22 of L6O PagelD 587 '3-_¡ et' g. Eha.t the so rosolu'bions bo sÞr'ooal upon our nímrteg anù copios carrylng tho signattrros of our pastor a,nd" cLsrk of Scssion, be furni shsd the Ðoirton ChuroÏt &nd t.rrsr 0a1braí1,h. $assiort closoct with PTaYor. îr. r ¿' s .Decenbor L4th,LgE4 $unday. '[he Seseion o¡enocl '¡rfth 'pråryer. Preseut, f)r.ll/m. j\ti.Àndersonriitlodorator, ;i)16ç;ta iì. ö.3s.herr lVrn.3aco:n, S.lf .BrlckerrJ)awrenco 'fhomas, J*ir.3ri0or Par:r-I Kirk;pat:lickrR.I{o.}lab, J.,ü, Stephenå, $. 0. ilic"ßra.d denr S. lir. G1aegorl'r .Il. Croãier, j,...., Cou1 te r, t\. D. Ho ilp;e , 0. f,. ll. J. Voorhls a.ndÌ M.lU. rlrhompson. ìl i4I1leon, J. D.'tranÞ/ink1e ss, Il, ,ï.1¡owe , R. Jr. Stennf ir/. R. , h{o st lleoefvod on eïâInfnlrtJ.on,.rllalter Soruuggo Curuth,oh Letters, Ir{rrlb lilr€.iL.:,t/.Hlll"monti :l,yorn .t'lrs1; PrOehy'tef f "rD 0huroh,llorrstOn, Iexas,],'lr.rlhotnrrs $.l.lelker from I4.lü.Church,Gordon,'Ioxas'Jl4r$¡. lhonûLs S.liialker :f :ro¡rr Bapttst Church Gordlon, Texas,Ifr9.\'ú.Ivl. Scotlb .from .Presbytorian Church, Beaumont, Toxns, anrl I"Ír.&l.h[re. ¡Iroh trt'unn f rom City 'Iern$le , Dallag, Tercas . 'lhe Ëossion cl.ocred wlüh Þrrùyor. ) AllS Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 42 Case 3:13-cv-038L3-B Document 27 Filed 09/30/1_3 Page L23 oÍ L6O r04 Pag elD 588 \ HBSOI¡VED: o subnit to our oongregatlon e obligatlon of our churoh, alse our Br€rata of the byterlan Church Expanslon ln lngs to that Report of funcL. Sunday Sahool Supt. roo0ivec[. Iltotion ad.opted, authorlz fng 'llreagu.ser to pay abou't 1i940.00 of €xBenses of tüise Rowera Dio key to Young repBlos LÍlsslon ¡-]Convsntlon at Atlanta, Ga.. ,Ig*y. 89th, l-9âf. W Report of lür. l. A. Coultsu on }rl.ens lt/ortc r€coived anrt approvê "Q p¡t o il, Sosslon closed r¿lth pr&y€r. er ^{s,w pallae, o €g 'J,l€:ras , JJ€c. 20, L926. Sunclay. fhe $esslon oBenecl wlth prayor: Present, Iild.ers R, û. Stennle, It,tod.ef,ator, L. A. Bogers, g. .û,. _Iucs,s, J.,_ D: ^ $!ep!.ens, V/n. BAoon, J. D. Vant/Ilnkle, Eçwfr_r, pau'L lßrkpãtricÍi, s. oi tuoÉaaaeñ, s,, H. nrÍóter, !.w.. Tr. Couilter, B. t6l. CLasgow, J. l. lrioe, tráwuonce rljho¡nas, _ 4:. ancl !I. N. Vfl,ggine. Reoalved. on exÐ,rnlnatlon,' Mrs. ï[ooô Ba¡ton entt Mf ss s].oel¡len Ha].lle Fleld., Sessf on cloeeü wlth pra,yer. ? oÏl. Al 16 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 43 Case 3:1-3-cv-038L3-B Document 27 Filed 09/30/L3 Page L24 ol t6O PaoelD 589 ". .q!f '...,.4. . i; JLFvtl 1.8, 19i.ì6, fiuncla¡'. ll.he $esslon openecl l,¡f'hh pra,,/er. Present Dr o r.';rrr1. I{. JtndeT,Éon, ¡ìroclerntot'; B].den¡¡ R. $. Balcer., i',. |r. Ro¡Ee?s, A. S . Stel.rer', S . G , iricFacI.cle¡tr J. D. Vanlillnltle r B. i'], Glast¡oîrr J. TJ. $te1:lreno, T.l'¡. Iirv¡in, H. Íj, Lotye, J. li. ftrrtcirlnoon, C. I). Shar'¡, C. P, ÍJlte *, Íi. Il. Br'lclcer, J\'. D. IIoclg.e, C. L. I,ioes, PauL lllr.ltpatriclr, iì. j,. ËtennÍ.s". i.ìt. Jlacon, G. A. ï,ucas, L. Â, Conl1;ot, J. i,. Fr.5-ce, i-.. D. Prlce, I_rr, Iì. trozíer ancl llrr. -i, 'fholrli:,1on. F.eoe1veci. irf:re. J. P. Ba1lier,¡, I,.tiEs L;ilIen Lef brqic h, I;iisçj Dovothl¡ 'feIfor.cL, !'irs. 11. E. ÍjoutJ:r , l.irg " F. 1:'. ,^,bernâthl¡, lilrs . 'Jii. i(. $h.eIton, Iflss iL,ary ï,Ia rgat'et Dyer' :rncl Jeßsie D¡rer on e-,í* anilnat fon; i.ir. 0. in. i!,/e:.. on restal;enren'l;; ijir', I¡.',1,'. by Lettet fl.oln First iriethocllrrt CITurch, F{i. ;.ori;h., '.l*ex. l,.is$ .iinnâ .Â. ltrol.l. :;':'rolr Ci-ty ï'ernp3.e, I)al-lafi . I 'fhe sc¡ssion closed lri'bl'r prâyer. "/t.i:r"11 Ðî, , 1.0Í16, ÍSr-rnc],ay. The sesslon openecl :;iLh p-rayer', Pregent Ðl:. r,.'r¡r. I,r. "1ncler¡,¡olr, h.oclerat-,or:'; Iil-cì.ers $ . il. Lr:tfclren, Ti. P. Ï,'1J.son, 0. 1,. l;io$Ê, 0. l). Íiiray,l, J. D. VÉnl rlinlcl.e, I,arence -fholuas, i:.. I,. [ltennit, ii. i,. De)cer', 13. Ci. i,:icIïa<lc'letr, T. fi'. Ðrrzin, i,',,'r1, Bocon, ii. li,..liör';e,.T. t: PrIce, J. L, Íitepheno, Faul iîlr"trr:paLnior<, Itr. J, Vo.orhÍ6, J," Â. CorrJ-t,er, ' J. ll. llutchlnson, f). lì, Irr,j.oe, i,'. 1,1" iï:l¡qg:ins and ii. ['i. Thorrrpron. Itecçiverf I{r. J, F. Glolrer ancl. Jrir;r. J. Õ. Olj.ver on e:çånluatlon; trU.ss Cl"arn riI¡¡no t'iorg:an on rest¡lte¡rrent; hir. nnrl ilir"Þ, C , B. Jone$ ìry l"ettel' fïom 'Irlrrlûy PreolryterÍan 0lrurcl.i, Da1-1as; hïrg, $, lll. lr,'r,Íßìrt fr<¡rr, .r',1"rbey' lrreol:yte-¡'Inn Churcll, Da.l"l.r¡.s; _-Tirr. ancl tçir,.,¡¡. v. ili. lliiokel-1. froin I?arlcvay preshyteri.an Church, IJall.asi l{rs. IJi;ha l1¡l¡ott fr.o:n l.'lrç;^b FreiliyterJ.ån clru:rch, "{rustin, ïlex.i iÍr. ,). c. Ollvey frollr Ï¡ire'L r.,t'eslryterfan úhnt'oh, DeÞor1;e 'l'e?1.; i,ir. iil. T. (Jl"J.ver îro¡t Ρlyst Fres'tr;¡tei.:Lan Chur-¡.ch, i)eport , Te)i, , *r¡cl. i,.rÍ..i. i:^. l;, 01lve:: fr,orr¡ l.¡il'st Dant ist Olnrrcþ-, .Da1Ia,."¡. The fol.Lo','ritr6¡ ïIeT'e f.jrân'üe.l lei:ters 'bo 'bhe I'If61h1anú Pqrk I'reslrytexlan Church to be ofgan:ì-zecl.: ir,:'. nncl iiifts.' C, I', anrl C . ü' , "4ncleroon, ,Tr . , i.,ir. ancl i:lrß . :i' , íico1;È Cl"arli, ìrlr. êncl. f,!r,s. J. t. Cor.r}son, Ifr. and ilirs. I.Ienry il. Davis, liiïs. lSyoüks 7" Dlcltey nncl iloviena and iriart?re. rlr"oolis Ðicirel', í:,r. and l,'il"Ê. l,fþ6r"1 i:i. Es'beÊ, IÍrg. Iii. E, Forrer.ii', ìiil". ancl. iïÍrs. ,i¡. .4.. I¡oscli-clr, Íîr, and. irlrs. i:i"' 1{. ancl l'lhltenton T-fqnfler, it{r, ancl j,fr$. i'ìal"e1¡*1r ¡lnci Bal"efe:!r, flil:rtenst:l.ne, ff., lfrsi Ií. P, In¡1en li?. ancl liirs, lr,urtem D, JoneÉi ancl ':'ii::t ì:ig¡lsi Jones o 'l,Ir, ancl i,frg. I',rib,l'k lrer¡rnon, Hrs" ìT. L, L€rûloh, î,'i'¡'9" i. Ð. Le¡llk; and ilonnÍe IrouíÊie ¿r.ncl" Pr"anl.r . LeslÌe, iÍt:, atrd ,,,ïire. Joh:¡ i-i. ldal:ry, i.i.rg . I-1. IJ, i,eirrlthetr, i,irn nnc.i iiils. Clrarles Lee i;.oiiulty ar:cl- Jane í:jhervroocï. ancl Cl'u,g. 1,. j,çI{q1fy, Jt , , i,'rr. ancl i',irs¡. J. S. Pul"lfam, iiir," anc'1. î,i:'r¿. iigi'11 ïi. l'.'ee¡rß a.nd. llv¿r T,ynn l'iee:nS, Iilr. nncl III:s¡. I I I I i l i I ¡ I I I : i i ¡ l I Cf A-117 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 44 Case 3:13-cv-038L3-B Document lPO 27 Filed 09/30/13 tenton, Lrrr. and llrs. Cleo. E, sesston ol-osed rvlth þråyer. Wf Page L25 of tkin L60 PagelD and. Miss Lynn I Dallas, ÍIexas, May P, L926, Sunday. l[]re eessf.on opened ,¡vlth prayer. 'Present Df . Wm. M. Anderson, Mocleràton; E1ders I¡êw*!; rence Thomae, S. If . BrLcker, J. I,, Prfce, E. .T. Voorlrls, A. $. iSteirer, Pau3" Kh"lrpaür.ick, G. -4., I",uoeo, B, V,I; GlasBo{, õ. L. Dlosc, J. Ð, Vanliflnlçle¡ [i.0. lt4cFadden, ll. D. Hod.ge, FI. L. Stennls, J. E. Slutchinsonr'¡im. Bacon, R. JJ. Pnfce trnd M. n'1. Thompe oÍI. Recelved Êdwin B. Jordan, Geo . Jord,sn e Jrr, , ThoE. llndere oor ,fr. and iVlrg. Vernon Col-l"lns on oxaml-nat 1on; IVlrs. L. @. Brow n on restatement i Mr. and ifir6. Geor.ge R. Jotclan, Mrg. C. C. Senter , Mre. B, .O. Duke, E. J,/l . Rlggs, Mng. E, M. Rf.ggs ¡ MrB . C. !. Rhoa, Mrg. James L. Rhea ¡ lt/b. å nd Í,{rs. Thos i Anderson aúd, lVlrs. i{aII Shannon fr'om Presbyt erlan Forney , lex, ge*sf on olosed w1üh prâyêx'. Dal-Ias, Texas¡ May 9, L926, Sunday. ThÞ eesslon op€ngd wlth prayela. Fnesent Ðr. ìifm. M. Anderbon, Mod,erator¡ Eld.ers PauL KLrkpa'tr"i.ok, J, L. Prioe, I,. /r. RogorË, Lawrenoe 'Ihomag, R, L. Stennls, R. S. Baker, E. iI. Voorh1s, A. D. Ilodge, S, ç. McFaddeh, N. A. Cnozf.err'J. L. Stephens, J. E. IfutohLnson, O. L. Moss, J. D. VanWinkle, l. W. Er{lfn, B, W. GLaågoty, Wm. .Baoobr -G. A. Irucasr S. H. BrÍcken, ând M. M. îÏrompson. t Re'oeived l¡{rrs. Dora llVaynerReðman, Frank fhonag Bennett and Phil-1p l,lndsley¡ Jr.¡ on examfnai;1on; and Mr.6. A, W. Erviugç, Mf'sB Mlldred. Ewfng Anna. Rusgell Evrrtng by let- ters f,rom Centràl Presbyüe Btolr'Va. foJ-J.owlng: DlsmiÉsed to' Illchland E. E. Ot'oulell,, Mr. and I[nB. Vf . D, Cãnpent nd i\tns. John ÏU. lft'Ë. I-,.. ß:. Ðyke, lüFÊ. Br¡¡.ks G Lonly' Ttl, S' K5'zel" End, Al-ice-I(tzer, I,/b, a Mrs. Ol-f-vla Lemlyr Jr.r Ellzabeth and Jo ;Moorer 14. and Irester and lvlar Lester¡ Ii43. an SanE. orr, and MrE. J. ooúothy Mr. and MrÉ.ìff. W. 0rr d,uslry' trÍr. and ûlrs. ELmer-F. E. Sohmid.t, l/[r, a¡¡d Mrs¡ fü:ÌIä't,uäAè änd lerov-wããã'-tvtr. anå ùr's,'If. D. Yopp and Al18 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 45 Case 3:1-3-cv-038L3-B Document 27 Filed 09/30/L3 Page l-26 of 1-60 PaselD unt Iionbense and Ânnette Ëarn. The eesÊ.ùon closed v¡i.th pra./êr. Da 1la e, 'Iexas I :il- ) , liay 3"6 , 1.9A6 , Sunday . with p:royer. 'Itre sesgfon opene<l Present D::. llin" 1,.. iìnclet'gol1r I'{ocienal)or; ¡llders L' ,i. Coulter, E, ï1. Olasgot't, J. D. Vanlïinlrle, J, f,. Prloer Faul Illr.lcpatrick, R. Ë. L'ov/e, E. J. Voot'Ïr1s, I,l. R. Ct'oøierr C. L. iliogs, A. D. i{ocl6e, Lavrence 'lhomas, $. G. irollacldenr J. t. gtephens, J. Iì' ilutohinoott, G. A . Ïruoas, $ . ll . Briaker, Fì. L, Í.:tennfs, 1¡i. Irl. }illg¡¡1ns ancl I/:. fi'i' ll'rornpoon. ilecefved ]ilrs. 0. C+. l;oacle on vestatement; and fuir. end, rurs. 1.t/. Ii. Frierson and Hùsô Íial..lle Ïþlereon Íry J"et{:er fro'm l¡irslr Presìrytenlan úhurchr ly1er, lBx. l.lotion adopted that we reËrl:ire tire ïlcdnesday night prqyer neetfn4s aff;er Chu¡'olr l{i¡¡ht 1s disoon'blnuecl for^ the gu.illner r Per¡nlssion ¡qranted Llvangellst, Jolrn Ilvotøn tire churoh Srrnclay afternoonr i;iay Ê5d. to ¡rreaclr Ín J-loarcl in ¡rIa R. C . ÍStubirs eleotecì. member of JSxpatt$J-on of J, $, PuLliarn (ruovecl to ÏI;Lghland Par'lc Chr,rro\). The session cLosed '¡iJ-tLr praycr. ";r,ß, Dall,as, 'Í'exÊs, ii'lay i50, 1926, $unda;¡. the øessLon openecl lrtth preyer Pre$ent Dr. Iim. i,i. Ì,nc1,erson, I{oderatoir; ELder.o I-,. l!. Ë' t. i'rcFoddenr F' li. lover Güoul.te:r, Faul fti.rkpa'bnlckr /,:,. Irucas, ì.ir. li. 'tiilson, /I. Ð. 1loc16e, J. -l'. Prlce, C. L. I'r:îis, Cl. D. Shavl, J. fr. Htrtchin$on, J. L. $tephen,s, flm. JJacon, Larlrer:oe TlrorruÉ, lÍ. Il. iTi¡151f.ns ancì Ii,. i',i. fhontpso:. Iieoeived tir.s. D. S. tieaver and. lire, li. .É,. Logan on exanrinat iolt. Tl:,e sosefon closed v:i-1uh Dal-lasr Texas, June 6t L92â, Sunday. The eession oile nod Present 'llth prayer. I,ioderator¡ Dz', \ilrn, î,1. JLndersor:t^, ELders PauI Atr9 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 46 EXHIBIT 2 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 47 cTX i eô5.ITt ht7_l 00¿00ü Y85¿L'ì11,1 (i¡06å1175 0Ui, rt¿ \ HlSTti{Y üF fHË H I6HLANÐ PARK í'iI Ë5 B 0ALLAS PU.iìLIC LI¡ri.ARY fEXAS AND DALLAS HlSTORY a Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 48 0t a¡,tar, r/\/teü'^bars Mr. and Mrs. Emmet C. Munnell M¡. and Mrs. C, F. Ânde¡son Mr' and Mrs' L' M' Qrke Mr' and Mts' Entler Edwa¡ds Fulle¡ Anderson Mr' and lvfrs' Dan English ir" "ìJuir. riank Bell ^ü;: and M¡s' A' H' Btes ;;ã ui'' -Bennett l-s. Bennett Mr' Mr' and Mrs' J' A' Farmer ]ãiì" ù.-o" Mts' M' E' Forrest , irfis tyn.t Bonney Mr' and Mrs' \Ø' A' Fosdick Ho¡tense Born Mr' and Mrs' J' D' Fowler ,{nnette Bo¡n Jr' i',ft;ã Mtt. Hut.y F. Bovd J' D' C'Fowler, L' Gar,teg -Mrs' Mts. \1. Ii' Btools U.. ".¿ Mr. and Mrs. John V. George B'""1" i;;;;;;'-H;ì;; Mrs. Hugh Ë. Munnell lvfr. and Mrs. J. F. McClue Mrs. Lois V. Mclain Irfr. a¡d M¡s. C. L. McNultY Miss Jane McNultY Nfr. and M¡s. C. C. O'Neal Àfr. and Mrs. J. C. Oehlet, J¡' M¡. and Mts. \7. V. O¡¡ Dotothy Orr Mrs. M. Â. Orr Miss Ella. Mary George iri"wÑ.ll-stoott M¡s' Burks Gossett ¡. li. n^tr.t. J' L' GraY Mrs. R, E. Buckley jolü s;.kr"v i"lrs' C' F' Gribble Mr' and Mrs' K' H' Harger í"ã*.ir s"åkl.y rùlhit Hanger Ur. and M¡s. E' lf. Burbank M¡' and M¡s' R' Hortenstine iÏirt ¡,r"ivã"r¡q"L Raleislr Ho-rtenstioe' Jr' s;iÉ^"t iärã Mrs' H' P' Inge í'rir. r. i' cu¡tt.. lvliss Âdelaide Johnson Sirtley C"inet i¡i.. ^ü;.-"Jñt. Mr' and M¡s' Robert o' Jooes þhn \t. Ca4reote¡ ' Mt' and M¡s' \{/urtem D' Jones nìI.r, òt.orvn ca4)etrter M;. ;ã M;t. Lewis T' Carpente¡ \firt Reme¡ JongsMr' and Mrs' J' \?" Kizer Thomas A. Carpeotet Àiil M;t LewÎse Ca4rente¡ Miss Alice Ki-e-i - Lemlv ü;:-";d ilÃ:!ø. D. Cìrpeoter Mr' and M*'Y's' ,Oø"t,". C"æ.n,.r, J.. \øilliam LemtV Miss Elizabeth læoly Evan Caçenter i,frs. \tr. Scotr Clark John Lemly _ fnfi. "ná õfttt, ¡.. Mr' and Mn' Ma¡k Lemmor V.'S."i Mrs' V' L' Lemmon Mru, ti' x. Coke tnl.. ""¿ Mts' J' D' Leslie.. f¡.sõãi., ¡t. ^¡ìì."""¿ Leslie ilti. ¡. T' Coulson Mics,Bonnie F¡ank Leslie M;: ;;ã tnr.'. V. r,. cor M¡' and M¡s' Max M' Iæster Miss Lillian Cox M;:-""d M¡s. Marvin E. Croom M¡s' O'-D' Les-te¡ Mr' an{ Mrs- J' S' Mabrv M;.;d M,s. E. E' cro*ell M;. ;;ã Mts. Henrv R. Davis Mrs' M' M'M3I^ M¡' and Mrs' M' G' Lipscomb iri"ry i'r*ã"i.i o"'iit Ma¡tia , . õ.Jlö"V"ã¿v Mrí. sÃãk r.bi.t.v li"r.¡t bi.t.v' i;il R;;;" Di.Éy Itä"r I,i;.-;i M'i iot" É. Dunla¡r Mts' G'rr" Miss Ruth Martio- Mts' H' E' Mer¡ithew Mr' and M¡s' M' Il' Moo¡e M¡s, E' G' Mugfotd Ivfrs. John B. Owens Virginia Owens S. Pulliam Marv Ellen Pulliam Mr. and Mrs. J. Nfr. and Mrs. Ben S. Robensoo M¡, and Mrs. J. E. SanduskY Mr. and Mrs. E, F. Schmidt F. Shaw Mrs. Miss Ma¡ion Ethel Shaw Mr. and Mrs. I?ileY E' Sim! Lfiss Sue Steele Mr, and Mrs. Charles S. TeePle Cha¡les S. TeePle, Jr. Mr. and Mrs. E. P. TemPletoa Edwin TemPleton L. C. TemPleton Mrs. M. J. TemPleton Mr. and Mrs. .,{. M. Va¡ce John Dean Vance Mary Lee Ya¡ce \f. À. lvfilton Vance À{r. and Mrs. R. M' Vaughal Miss lvfarion Vaughao Robert C' Vaughan F¡ank Vernon Mr. and Mrs. LYtle Wade R. L. \,)Øade Mr, and Mrs. Sam R. \feems Miss Eva Lynn !Øeems Mr. and Mrs. V. M' I7hitenton Mr. and Mn' George'S?ilkin Mrs. C. E. \9ortman M¡. and M¡s. \?'. D. YoPP g0derc and Oeûcorrs Clurtter, Dezcon¡ Ca4renter J. T. Coulson Henry R. Davis Ralegh Hortenstine Elde¡¡ Harry F. Boyd Lewis T. Caçenter John John W'. George R. M. Vaughan 'lf'. M.'Whitenton \f. Ma¡k l¿mmoq J. S. Pulliam Chatles S. Teeple Sam R. !?ee¡ns \7u¡tem D. Jones c rx ò5 ¿1,111,1 R Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 49 , )4 \i. Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 50 CHAPTER HERE AND I NOI\I resbyterian Church' as we see it in celebration of its fortieth anníversary rastic rernodelling project has been comnning this tour of the building in what And why all this attention to a buildt Part of a church? The answer is that this survey of our church today is for both the Past and the future' at the persons who make up the church ent of soul and fellowshiP' LastlY, ds one look at the whole before he s, so this famiLiar view of Highland cate places that have changed through you as their many the years. And it is hoped our members will come alive for and varied activities are described' gray brick and stone A handsome, gothic-styled building constructed of warm up most of a long takes with a decorativå ãpatterini of ivy, thã church proper Shannon Lane and Park block, bounded by university Boulevard, McFarlin soulevard, jewel-toned stained and Street. rne sanctuary with its ta11 graceful fleche right here' glass windows faces UniversitY, so let's start our look at the church room on each The four massive oak doors open on a sizeable narthex with a with furnished side; the one on the right, the ¡ri¿e's room, is carpeted and strictly is loom sofa, lamp, chairs and such; on the other side the ushers' utilítarian, with tables for the collect Beyond these rooms on either side are s a literature rack, we enter the sanctua aisles, changing to oak flooring in the stained lightly (but not blonde) and th the our comfort. As we approach the front of the church, it is evident that pew the Iîatches red carpet, leading tà'tne platform and covering most of it' for the choir is on each side, with the organ at the cushions. The are rnade ""u[ing rear. A speaker,s stand on one side, the round pulpit on the other, church of the rear of oak carved in symbolic arches. A conmunion table in the steps' platform of the bears a Celtic cross and flower stands are on either side The sanctuary has a hushed beauty of its own, compounded of its cathedral not ceíling, effective lighting, the glow of color-from the windows. It is services three place for difficult to visualize the Sunday crowds that fill the every week, at 8j30, 9:30 and at 11;00. our smug pride in all this is somewhat Sunday dashed by recalling the remark of a friend. "1"'s been to church every be true? Can this for five years and no one has ever spoken to me." others The sanctuary has room for only 1,25o, So on special occasions, where Ha1l or Currie Chapel Wynne go to of our more than six thousand members other they share in the worship service by closed circuit television' Every service 11:00 the and channel 1ocal a over Sunday the 9:30 service is televised may be heard alternate Sundays on radio' 2 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 51 there is a long hall the sanctuary' When you walk around behind in the center is a north-south east and west; through a swingrng áoot floor has more offices" oo"nl--à onto which the ctrurct offices "l runnl.ngi co rrid$ r ""co.d 1et's and quarters of the staff' sanctuary the at look quick this out on After behind the sanctuary and ïrt"-r,.ír tä nact rittr". steps-á me our retrace Building' Pause with iþ Educational itt" to way our on we're door the east Especially lovely in Spring c.ra""-. schoeritãpi the admire to the colonnade and trees and vines' wit¡¡ snru¡9:tt^ of riot a are azaLeas -ate when the "oiãr,'ttre sight at any time' a refreshing wide brick walks GoingintothéEducationalBuildingbyeitherofthewestdoofs,v]€rìof,g and tile on walls and floors' Even approvingly the gleaming f-reshnesã-ri-pri", construction' all this wing h4s' finished n.rry the of part nót is though this beenremodeledandrenovatedintosornethingnewanddifferent"onedoorleq6s equipment hums, and multifariouq to a basement stairway where tr," r""rranical is next and then a pairofof building The boolç items are stored. ";;i;;;t;: ?{fi"" Library in its enticíng artay glass doors o"rrra ã"árl*p"" oã tnã Church carts' ]actets, shelves, tables and book JustbeyondthelibraryisaroomyclassroomandacrossthecorridoriS school; through the windows we adthe glass-"nc1o"ed orr¡."" of the cturct''day mirethedivan,upholsteredin'".oo,,leather,theseveraltablesandchairsi addition to the secretarial desks' Walkingaroundthegardefl.¡,..1!'¡ì)!-Lhelrewmarblestairwaywecometothe nurseryandkindergardenchurch.schoolclass'oo'";insidewegetglimpsesof mobiles, closets ful1 of interest: what goes on as expressed in wall ãecorations, ing things" Goingalongthenorthcorridorofthisnewwing,theUniversityBoulevard i" t """oãf marUfe stairway'rflante¿ door opens on our right and straight ahead t*by an adult classroom. window featuring a wñite Have you seen that eye-catching white-curtained beds that are full on Sunday' Walkbassinet? Behind it you can see ltoã" tobaby coürtyard windows overlooking the paved we come ing along this east corridor, jungle ínother grm' mllry-go-round' swings and on our right. The sandpile, by the day school students" triguing playthings are use¿ entúu"iã"ti-"rl1y First-gradeschoolroomsthatdoubleonSundayasclassroomsareonthe oak double door opening or¡ left and at the end of the east corrídor is the McFarlin Boulevard' MoreblassroomsopenoffthesouthcorridoraSWelookoutonthepeved mark the Going t;;.;g; the double oa : doors that courtyard on our right. end Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 52 3 ñ the Church parlor, a spacious friendly Toward the end of the ha1l is WYnne ay leading to the church offices' 1,,' ,::.: . , , r elevator) ginal entr an aÞ ristia tion, uth co ;;;t-" the square eed along s. The as ubicle of eft at thi Pel; then oms rom , second fl take a six s e west ional Builduse the wide Place of lovely garden he east ha1l" the bight as we You get a Pass bY manY . with a seating capacity of about 400' om McFarlin Boulevard by a gently sloping one end is balanced at the other by an as I¡1. Currie over the mantel" .: ' ' /t.' ;g¡.tcÌl,tonsandsuchare.prepared,withthetablessetupinthe ,.raIt¡ '..'} For srnaller meetings sliding partitions insure privacy and better acoustics' through , visit the scout Room, turn right at the foot of the stairs and go such, and cupboards . u 2assageway. Here is q, Large ,óo,n, pine panelled with week the through iui. ,), rquipped ior scout meetingã, The Scout Room is used for their weekly by bgth adult and younger handcrafteis as well as by the Scouts I ; dishes and cooking utensils he kitchens, with their huge ovens, stacks of doors on each side' Here r.. lr of the alcove and may be entered by swinging -' rj : j meètings" across the street from the sanctuary on a Latge' treeshaded lot is a frame structure that is called the Youth Building' Here the seventh and eighth graders meet on Sundays and here various meetings can be scheduled through tñe week. During the irectic period of building and remodelling' thls modest buii¿ing took care of most of the displaced classes and personnel' On Shannon Lane church ever to be so honored, Highland Park Presbyterian Church in August, 1966, received an award from the Men's Garden Clubs of America for excellence of landscaping. Only ten awards were âpproved this year from the 300 clubs throughout the United States (and no other church). Members of our Property Commitlee--Ea11 N. Jackson, Harris A. Kemp, George W. McDaniel Jr", lfilliam D. Kiebler, W. Dee Downs and Barton B. Wa11ace, Jr. accepted the plaque describing this national award for civic beautification. The Property Committee is responsible for our church plant as well as the yard and grounds. The first 4 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 53 CTI,APTER TWO FORTY YEARS AGO--AND AFTER i that in the yea r t926, all- elements we Dallas' the founding of a new Presbyterian church incomposed o ?resbyterian Extension Board of Dallas and U' Churches' one deacon from each of the Presbvterian tt'" l-ocatíon of new churches in January, When the various "ttå"";";^'f;iiF,¡ãt for the that the most promising^section were surveyed, it was agreed ,rnurrîiou"ly area' Cities Park pårk and the present location of a new church was Highi."à It seems daYs, Mrs' Mark Lemmon, one of For an informal descriPt ion of those earlY Park rr If anYone fee ls that Highland the charter menbers, recalls wha t happened: called that person e My father was th Presby terian Church is 'his Church 'Idoi of L926 to talk in Ja nu together e ^1y a little group of interested PeoPl rch" l{Y earlY T" ReYnolds' ge Geor father' Mr' about forming a new PresbYterian Chu in Da11as (alt here rches chu President of the Extension Board of our PresbYterian of the Pres bv-l Committee of Home Missions Executive the on lso a was time), M ,"1 that McMillan was Executive SecretarY' in 'an Homer Dr' which of So U. Church, terian (He was also Present meetings" Reynolds P resided at the two orga nizational new buiLding much lat er the in official ca pacity at the time of our first service --when Dr. Homer McMillan preached' ) and feasibilitY to discuss the Pos sibilitY "We met one SundaY afternoon to talk to praY, to t was asked to think' a new Church. Each Person Presen second v The ussion. y for further dísc 1 f riends and come back the next Sunda organizatío An ntze. orga to there was so much interest shov¡n tha t we decided Sam ltleems, Mark Lemmon, J. committee was appointed--Henry R' Da vis, chairman; Hortenstine, J' S. Pulliam Raleigh Coul son, Charles R. TeePle, John W' George t en" Ws were in PrePar ation forask d happ to began things and ülurt em D. Jones--and ization, In March, 1 926, we months b efore we were ready for a formal organ Pres bvt erian Church, to advise with Dr. William Anderson, Pastor of the First o f Church Order of The PresbYon the proper form so as to conform to the Book terian Church, U. S interes ted was held in the Highland "The first ge neral meeting of those th ere were 53 Pe Park Town Hal1 on APril 11' L926. BY this time e our Church. org,anaz a petit ion to request Dalla s PresbYterY to to proceed wi Texa s ,. on April L3, L926, we were given Permission Lesl,ie, Gene ral AssemblY' D. J. Dr. organiz ation. Officers were then chosen. E. C. Scott was called as SuPPlY Stat ed Clerk, directed us and The Reverend Pa sto r. L926. Then in May charter member list was formed in April,the total to 190' Dt' 1ist, bringing some additionaL persons were added-l; the get startã¿ ih" """ superintendent of us H. s. springall was untiring in n"rpirrg t,tii,tg elders were chosen and nine Home Missions for the Presbyter/). File w. George, Lewis T" carpenter' deacons. The elders were: Harry F. Boyd, Johnwere: ;ãnn w" carpenter, Henry R' R. M. vaughn and w. M. Whitenton. The deacons DavisrJ.T.CoulsonrRaleighHortenstine'MarkLemmon'CharlesS'Teeple'J'S' clerk of the pulliam, Wurtem D. Jones and Sam Weems " Harry F. Boyd was elected Hortenstine Raleigh diatonate' session; Henry Davis was elected chairman of the collection bhe days early secretary and Mark Lemmon was nade Treasurer. In those was from $5.00 to $6.00 a SundaY' ,,The 5 initial Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 54 rAbout that time the name Highland Park Presbyterian Church was chosen After much and adopted. Next, where should our peÍmanent Church be locabed? looking the property on Uníversíty Boulevard was found--9"85 acres-'-more than a- ci,fy-bLock and the down payment would Ue $fS,000.00" Mr" Reynolds appealed Éiome Missions and they agreed to give io tnä Assembly's Executive Committee ofgifts from the Church members" So in u" $Z,5OO"OO if we would match it w;ith property which was priced at $521500"00" itrt "ry we got our down payment on the Several deacons went on the note at the bank so we could start a building prog,ran" We also made a trade with University Park--if they would cut a street Ifrrougtr our property and pave it, thereby squaring up the block--we would in turn áeed the land east of the street to them, to be used only as a park. Some property on the south side of McFarlin was sold to Dr" John L, Jenkins, other lots were sold. This sale gave added cash. So by now we had concrete plans for our Church home. 'tThe pulpit committee kept us supplied with a minister each Sunday, whenever Mr" Scott was unable to be present. Our Sunday School was organized with Sam Weerns as Superintendent and Mr, W" A" Fosdick as Assistant Superintendent. The Sunday School classes were first held on the second floor of the Highland Park High School, now Highland Park Junior High School, on Normandy" Church services weie all held there, beginning in Ju1y, L926, untiL we moved into our own build- Mr. ing. committee was also constantly looking for a regular minister, and Reverend W, A. Alexander of Mobile, Alabama was called in December, L926" "The pulpit I'In those earLy days we had Home Mission and Foreign Mission classes in the homes of members. The deacons and elders met in the homes, too. Every rnember worked for our church, for we wanted to grow and be felt spiritually in the community. tt ** See Appendix for list of charter members. July l1th, L926, the first general Comnunion Service was observed--in the Highland Park High School, The following Church Trustees were elected on August 29th: W" M. Whitenton, Henry R" Davis, J" T. Coulson, John lt¡" Carpenter and Harry F" Boyd. At the same congregational meeting, purchase of the University Boulevard property was authorízed. On It was on Sunday, January 16th, L927, that Dr. W. A" Alexander assumed his duties as pastor although he was not officially installed until February 27th. A buil-ding committee was elected the following month composed of W; ltl' Whitenton, chairman; J. T. Coulson, J" S. Pu11ian, W, Scott Clark, Raleigh Hortenstine and Guy Cahoon" On April 3rd, six more members were elected to the building committee--C. F. Anderson, E, H" Blurn, John W. Carpenter, Henry R. Davis, Walter Hogg and Vlurtem D" Jones. And on April 19th, this committee selected Mr. Mark Lemmon as architect for the proposed church building" Mr" Lemmon recalls John W. Carpenter admonishing him with these words: "You'd better do us a good job, young man." (Mr. Lemmon has been architect for all our buildings" ) That first budget, for the church year beginning April lst, L927, amounted to $12,175"00: current expenses $g,ZzS"OO and benevolences $3,400"00, The statistical report to Presbytery which met in April showed the botal number of communicants to be 239 with the Sunday School enrollment, including Cradle Roll, of 310" 6 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 55 The contract for the first or Su was awarded to Bellows-McClay Construc ground was broken. A loan of $75'000' ír, order to simplify and expedite buil porated under state laws and on Februa state. Building was held at 5:30 in the The cornerstone laYing for the A lexander ta1 box Placed in the cornersto aft ernoon of Sunday, March 18, 1928. In the me members, a PhotograPh of the are a copy of the HolY Bible, a list of charter the church uP to that first memb ers of the l¡Ionen's AuxiliarY a nd a his tory of t ime. 1d in the Chapel on SundaY The first se rvice in the new building was he r officiating. The formal morning, August Lzth, 1928 with Dr. W. A. Alexande Pl ace September 30th at which opening and pre sentation to the cong regation took As sembly's Executive Committ General time Dr. Homer McMillan, SecretarY of the invitat ion. Joan Lawther was the first of Home Missions, fi11ed the PulPit bYAugust, L928' baby baptized in the new building--in It is ínteresting to note the fi mplished" Church Highl and Park PresbYterian (The Just what did this first structure offacing UniversitY Boulevard. comp risê? It was two-storY, rectangulat, was part of this first present north çorridor of th e Educational Building the SundaY School Building, building which has been call ed at different times ay School classrooms were Alexander Building or Educat ional Building. ) Suno all church serv were' downstairs; upstaírs were Alexander Ch ape1, where back of a sma1l cubbY holes held; the ladies' Parlor and kitchen a nd some a Pews and onlY Pi the Chapel. Movable straight chairs se rved as The achi evement of thl discomfort. anY of light the choir, bu t enthusiasm made high endeavor' first building was both a source of Pride and an incentive to the church's report to Presbylte.ry At the end of that initial five years,ichool enrollment was 795' l"o] Ll" showed a totât- of 683 communicant"; sun¿ay went to benlevototal contributions were $34,695.0ó, of "tri"t amount $5,919.00 lences. , Tn L932, Dr. Alexander indicated his desireBito him by the South Highland Presbyterian Church of was that Dr.. Thomas White Currie, president of-Aust o Seminary, became Stated Supply pastor in Decemberco L937 J. Ludweil Davis, Dr. Currie served through his work in Austin. fact Period. In HPrc g rew in number and sPirituallY during thisroperty to take care churchts P fabs were Pu t on the McFarlin side of the Dr. Cur rie decided to give overflow classes on SundaY. But reluctantlY time to his first love, the S stated suPPlY relationshiP to give his ful1 at Austin, to which he had dedicated his life" pf€-' ú1e mioa Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 56 7 I iiff- '1 x hwasagainfortunateinsecuringasitsnewpastor breadthofchatacter--Dr"HenryWadeDuBose_-whocame u,,ct,¡t,..r',spartanburg,southCarolinainJanuaryl938. spa"toraterDr'DuBoseenvisionedalargechurchand tfuJ- fears the membership increased' and a significant Lace ' sanctuary which was completed in L94I" ed the two-st'cry group of offices sorrth for Montgomery, A.tabama, in December, Gothic sanctuarye even as he had done at Presbyterian Church was without a senior l-liam M. Eltiott, Jr", Ieft the pastorate f Atlanta, Georgia, to accept the call of hip the church has made great strides in oLences and for current expenses. in membership, another building program This comPrised the new wing of the levard. Its two stories included many youth chapel upstairs. In the basement, for heating and air-conditioning, were as Currie Ha11, and several storage rooms" ,lril ,l ,t :{ I:l addition to the Almost as soon as this building was completed, another forming the southroom' choir parlor the and church was begun. wynne chapel, the the various time this At L952" in west corner of the building, t"r" "o,npl"t.a and its chapel wynne designed' Garden i courts were planted and the schoerrtopf were dedicated during the twenty-fifth anniversarv vear of the :', , ;;j;i"i"à-.oã,r" -Arrd.u".yone I took it for granted that the bui'lding program was comChrl'rch. , pleted for. all time. ilj;'l ,i, ,l ,{ I ,i ! ..,,"i., But in the early sixties, it became apparent that crowded conditions , ' agàIn hampering the wärk of many departments of the Church School and in L964 a most ambitious plan for adding io the first Xducational Building and remodelling r both existing wings was begun. This most recent project, the architect pointed :.,, out¡ has been the most difficul-t of all. The necessity for careful planning and I , scheduling of building was imperative since the work of the church had to contlnqe even as the construction proceeded" Heating and cooling had to be main' . tained even as a new system was being install-ed. Completed in June of 1966, the Present building admirably suits the needs of the congregation and is a delight to the eye of the observer. i, were i i ' ,] l: ' been necessitated by the inciease in our membership. The first change, in April 1945 marked the end of Sunday night church services; then on Palm Sunday, Lg5L, jhu dual system of services at 9:30 and 11:00 on Sunday morning was introduced" In January 1954, thi.s dual- arrangement was extended to the Church School, fn Octoberr 1966, a third worship service--from 8:30 to 9:10--was added" ' numbe¡s. ó , 208. cont ributions a 11 causes w"r" $r ,078, 039 " 00, $429, 436. o0 gotng to benevolent causes. Thetopresent plant and properties are conservati.vely valued at about five millionchurch do11ars. 8 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 57 ü{APTER III THE STAFF of 190 to a church ro Lof 1966' from a charter membershiP y a. with to $810'000.00t fron a church 6, 208, from a budget of $12, 175.00 our rYì t ificent building d esígned to sur bo rrowed meeting Place to a magn pired wiselY and selflesslY ins needi Who are the Persons who h ave sothat Highla nd Park PresbYterian is aPPa renb ma rkable devel-oPment? It rship that has implemented such g 1n deed been fortunate in the leade of HenrY R" Davis, ( That first PulPit SUPP1Y Committee, consisting and Judg e R" M" Vaughan q ucce Hortenstine h Raleig Pulliam, S. J. Whitenton, be remembered w ith gratitude, fo q cer: shortlY bY Lewis T" CarPenter), should Not life of the church are significant. tainly the first five Years in the it but ü,as SundaY to ay from Sund did this comm ittee keeP the PuLP itn suPPlied E" C. Rev" the Since r. as Permanent Pasto dilig ent in seeking a suitable maD a11as of the Clerk Stated the to as Assistant Scott, who had recentlY come to pulpit for several Sund âys, in SePtember, I Genera 1 AssemblY, had fi11ed our to secur e hís services as Stat the Session asked the ?resbYterY for permission b ringing to the congre Supply. Mr. Scott entered uPon this work immediatelY, From 1926 to tion a fruit fu1 ministrY" E. C. Scott that the congregation, with Rev' Addison Alexa nder, Jr., who was presiding authorized a call to Dr' William Birmingham, Alaba ma. On SundaY, pastor of ' Central PresbYterian Chur ch of as Pastor" January 16 ' L927, he assumed his du ties of Dr. Alexander was ^'i-..duate in L920 A native of tr¡obile, A1'abana, his KentuckY; at Loui svilläf Louisville Presbyterian Theo logica 1 SeminarY Cornelia' daughters , EIi-za beth Owen and was Elizab eth Owen and theY had two was Persuasive of humor, Dr. Alexander scholarly gentleman with a quiet sen sessed an oPinion concerning Policies in It rather than dominating; when he expre pleased to f o1l-ow his suggestions" church affairs' both men and women we reinfluence' would be diffic ul-t to overestimate his Dr. Alexander acceP ted a call toinSo After five Years at Highland Park' d the First PresbYte rian Church Highla nd Church in Èirmingham' He serve en went to the First Church in Shrev th Charlotte, No rth Carolina aftel that,FebruarY, l-956. He resi gned from the chu Louisiana in 1945, where he died in as he was i1l a long time" in ShrevePort seve ral years before his death, of those eatlY TaY 1or of Mexia revi ves memories A letter from Mrs. Frank t time there' tha At ttI came to th e church in 1930. years. She saYS' in Part: was Ruth time that Forrest" My name at was onlY a Part-time secre tary, Helen rking wo was I Vetera n's HosPital. Parks--mY husband was an inv alid in the a rY and sec¡et as come to the chrrrch would I if ed ask Alexander Dr. I when town, was called in those daYs ) (as title the ion Educat Religious of Director the educat ional work for six Years' worked in the- church office and did all Alexande r's secretaríaL work, was the onlY one there--I d id some of Dr. the m inutes for the Ses sion books for the church, Paid all the bi11s, wrote fo r the church in addi for the'Deacons, and did a 11 of the corresPondence We published a we church' ram of the the oversight of the educational Prog acceP n Annual" I left there Ln L936, news sheet for the Young PeoPle and a DaLLas of byterY theandPres Defendant's Affidavits in of First Amended Motion for Issuance of Letters for Rogatory Forthcoming Motion for Summary Judgment - Page 58 Education of Religious Director the position ofSupport It 9 was on December 5, 1926, , , hus band cane. to held for three having di ed in take Dr. Frank M' TaYlor, mY first of Africa) Virginia Pruitt (Mrs" William Pruitt woman? Parks was a busY Don 't you know Ruth rs L936 ' Yea mY P1 ace,tt t leaving to marrY resignation of Dr" W" A. Alexander, a 4, L932, aftetofthe On SePtem ber Mr. Joe E. Lawther, l4r' Sam Newe11, Mr' compo sed inted appo was to Pres ent names to the ttee Schmi dt and Mr. B. D. Hull Elmer Mr. liam, Pul This theY did on October 9 at a congregatíonal a new Pastor' for to him tion ' gg¡tfe$a propos ing the name of Dr' Thomas White Currie, A call was made meetlng ' a saLarY of $ó, 000.00 a Yeat" at thqt meeting at and Highland Park e relationshiP between Dr. Currie Thus beg àn a uniqu Dr. Currie retained years gh the time of the call and on throu the at for known as , Theological SeminarY, a nd therefore was alwaYs dencY of Austi n technical-itY mere a wa s in fact y for our church. However,a this sst true was Pastor to Highland Park Church" Dr. Currie obtained, r In a verY real sense and before Dr' Currie's consen t could be issued 1 was cal the r SeminarY the with Afte he was re ta ining his position be Currie ins isted that since co-Pastor a three or four daYs a week to the church that suggestion, ¡nd could onlY give his At salarY be divided between them. c4lled and that the sPecified as sist Dr. Currie. Dr. Jarnes Ludwe 11 Davis was called to AtthistlmeboththeSeminaryandHighl-andParkwereinfiñancialstraits--the ment was to prove beneficial to both inoved president and Highland Park obnown throughout the Church, a past moderagreat aUiiity and profound scholarship' left his mark on our church to this day' il' language of .-.1, .pr. curiiers sermons were arresting and often phrased in the just a fivewas our day--as his explanation that the meat dish offered to Esau nen's the for cent Uåwl of cþili, or his selection of topics for his lessons his train made he as : cl¿st oftentimes taken f¡om the-"iogun" of the day observed t: trlps coinmuting back and forth to Austin. : Hlghland Park grew under Dr. Currie's leadership and felt no neglect on the four day a week schedule. Dr. Ludwell Da Ct¡rrle wag able to carry on an unbelievab teachlng the Men's Bible class later name leaders for the women of the church, cond ' s $lC¿t amount of pastoral calling on the Adãcd to all of this our church record shows that he often conducted meetings and preached at the request of colleges and churches throughout the Assembly. s and Mrs" Currie, the three sons and gation. Mrs. Currie quickly made here Women's Bible Class, taking an e by her warm personality and devotion ch members not onlY as Dr' Currie's on. ving known Dr' Currie, a ttue man of d unassuming in his life in sPite of Sunday Dr. Currie preached at Highlancl esolve to become a glorious church in this end each Sunday he concluded his e members become a "glorious church l0 Judgment - Page 59 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary rk Currie and Highland he ped haPPY of have In the five years quali ties which in some measure shi those steward emPhasized the obliga tion of the home Church he cons tantlY us--namelY, efore lhesetb us to achieve the goa of the church, the sacredn ess of marria ge and with a the ecumenical mission ed his generatio n and his c hurch and his Masterof H:Lghla h¿ Dr. Thoma s Currie serv heart, and his spirit live s on in the rnemo ry and s inglenes s of mind Church' byterian Park Pres a He was stricken o'n Lg43" 2'7 APril on a ttack ' . Dr. Currie died of a heart sPeaking enga gement a from Austin to returning was he train as fellowshíP between Dr" StoreY' R" M' St evenson, Boude of 1ph consisting ee J t. , and l4rs" Ra A nother PulPit Committ W" L. Logan, Mrs" Bond, erl-an HarrY Theo, E. Jones, Harold Brand, inf ortune smiled on Highland Pa rk PresbYt left aga Dr" DuBose Howe wen t into action and Wa de DuBose " HenrY Dr. pastor t new CaroLina ' a Church in securing as its in SPa rtanburg ' South 1n Church erl.an PresbYt congregation our d lea to m behind him at the First hi insPired Dr" no doub t beautiful new sanc tuarY, whichGoth ic san ctuarY with its insP iring fleche" ion; he' and insPirat the building of our splendid withal a man of forcewa s real1Y "sh epneid of thern-gentleman sou true a was ' ing--he DuBose in their P astoral visit and ?a rk, church membershiP Highl and his wife were tir eless at remained he dea cons five Years he rotat ion of elders and h iS ffock.'r During t thought se DuBo sets Dr" DuBo and Dr" ers ring 1nc reased to 21042 rnemb was not adop ted du measure this woul d be advisable' Al though customarY procedure. ministrY, it is now Part of our :rízèd warrnt h that characte the Mrs" DuBose emPha sizes brim wi .th from letter gracious A Dall as were fílled to the in of ars five Ye the friendl ine ss their ye ars in Dallas: so"Our imPre One of mY first we arrived ant tw ere int e re st ing exPerience Ha the staY with were settled Ln the our members. We were asked to ev every of ust invited out for dinne t, aLl- six ¡ ma nse . young'couples who number of'atttactive v{as the by impressed iilmrnediate needs "I was greatly the ät"ãiã"t of o"" to "i" were very fortunate worked tosether îå'înå"äi"r"t,-s"í,";ï' peoplet o'rt fi;;-ro'r.e fo, and rÄac Kennedv" rea¿er"t,;.p trainea for Virginia_åÏ;rtîïî'rr".-rittïã*"ptuitt) ptrk oi church through the secure the servi""" H;;;î;"ã tt th;;'í,.;;-u""" what a sreatbLessing both yea rs. of Miller "Hubert HoPPer and Donald mY husband's during Ministers' made Assistant rich contributions to the wo rk Pas torate. rch doubled, there E ore de of the ctru t'While we were in Dal1as the membershiPm embers. The friendshiPs we rch calls on our new theY were th en" tt we made hundreds of chu to me todaY as during those Years are as dear as m þ I þ 39" Assista nt Minister in as Park hland Hig to Hubert Hi ram HoPPer came Church L n Houston' At onc ehe and his wife, and Park He came to us f rom Central for thens elves among the memb ers of the church, ace warrn a P1 his own--the First Elizabeth, made a church of for L94L in departed ctor of the Presa n everyone was so rry when he became Executive Díre he Later r' nto Presbyterian Chu rch of Midland"whi ch he reclaímed from obscuritY and made Doc tor of Dallas honorarY an ceived by terian Foundat ion in re he th9 of Te xas" In 1950 remained *1X¡ impo rtant Part of the SYnod of Y ears he number a For DaLlas Church Lî Divin ty degree fro m Austin College" of Glendale Village Pr esbyterian now is Pastor he but Foundation t Ministe{ ch urch as Assistan our to aLcalled was Miller In 1941 Dr. Donald G. as a missionarY in Korea ca me to Dallas wit h an ' an d an author" Dr" Miller, who ha d served as a scholat, a teacher reputation established ready Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 60 ll- In his pastoral calls, in his challenging classes of Bible study, in his encouragement to teachers and in his preaching, he inspired all whose privilege it was to know him, with a more wholehearted commitment to the Christian way of 1ife, rn his short time with us he won a lasting place of love and affecti.on in the hearts of the members of this church. fn L943 Dr. Miller was ca11ed to become a member of the facutty of Union Theological Seminary at Richmond, Virginia. He became a recoEnized authority on both the O1d and New Testaments. He is a member of the Editorial Board of e'Interpretation" (a Journal of Bible and Theology), is author of Volume lg of the Layman's Bib le Commentary and such well-known books as Conquegerjþ rqha:þr, E in My Mouth, and The Nature and Mission of the Chur ch" Since 1963 he has been the Pittsbu eo ob cal Seminary of ?ittsburgh, ?ennsylserving as Pres ent vania. are indeed fortunate to have Vírginia Gray Pruitt's reminiscences of her work with Dr" DuBose on our church staff" Here is her letter: I'Dr. DuBose brought me to the Highland Park Church in 1938 to be a youth Worker. I was not a Director of Christian Education, had not been to the school of training in Christian Education, but Dr. DuBose said that did not matter, What he really wanted at that point was someone to plan and carty through an active progran for the Latge number of senior high students available, and to try to maintain church ties with Presbyterian students at SMU. I was Virginia Gray at that time, daughter of a preacher in West Virginia, graduate of Agnes Scott Co11ege, had had a three year term in the Congo as a teacher of missionaries' children, was then teaching back at Agnes Scott. I was young, enthusiastic, naive, and dedicated" We "If I had knownthe degree of wealth and sophistication in the Highland park Church, I would have been afraid to come, perhaps" As it was, I arrived all eager, ready to pitch right in, and the wonderful folks at the church gave me a wârmr friendly welcome; the young folks seemed just as eager and ready as I, and we had a real fun-fine two years together, summer of 193g to summer of 1940. "At that tine we worshipped in the Alexander Chapel and the present sanctuary was still a dream" The church was growing rapidly and there was a spirit Dr. DuBose was a consistently exinistrator and beloved pastor. I great privilege and have ever since iples I learned from him" study and ask for my opinion, esth, or where there rnight be a difference church and the session, I considered eful to know and weigh the thinking of he would ask even me, with my youth en appeared to value. One conversayoung people should dance at parties nder first consideration at that period. s such, though some of his session did, eople danced wherever they gathered g its function if it simply planned nd that to offer something dístinctive, ip and worship that the church is rfAlthou th I was not a DCE my imrnediate predecessor, Ruth parks (now Mrs, Ylo r¡ Mexia Texas) had b een both DCE and youth worker and was at thaï rying on in both capaciti es at Presbytery level, wíth offices in Dal1as. ' L2 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 61 of Youth workr er") So I found r there was no new what mY a aI a PrebY- tl "Other nember daYs " The choir to'"t "t' ,'Arthur Harris was -choir iil:::::,"Ïlo*1""; ii::titï?i""ll;t"'g vor us of *u" ,n"0"-"0 "f a bunch was the Present one" about Dr" DuBose long it'ion ec aPPr day with great ma ral ca l_ls all thing I remember and could He "AnotherqualitY as a persono distress, b T;"'rì¿i sincere concern horne fo r the or h is marvelous e d inbo some o r sickness invit be sorrow not ed in would DuBo se with th ose ed with them, I he and Mrs. best wa s invit often I very Then when comfort and be the occasions a 1-n'evening" and, on the frequ entlay aside the c ares of the day entert a wea lth of th cou 1d wi he and r how nt humo ion and with anazeme good conve rsat of comPanY, full of relate" s to ing tales a nd exPerience thful activitY' ItThere was a bvzz of You was here and I shared wh en I got rnade KennedY dYMac ea r High School Youth "The off ice of high school aege th e Highl and ?ark of eroup big e caPtains fine, cam flocking, wa s a times when th so the crowds licitous group, fe youth those one of leaders in th e church teams were also girls. I came, then as many boYs as a rtment when DeP of the Senior wa s PerPetual treasufer and SeaY was President Mac Jr' Rush Klein SundaYs mo rn ings ancì for "Johnny Ma rk Lemmon, then bY son, e treasury" BuddY Hemming a' room furnished gua rding of th in building careful ra fbers en The his rY wood renowned for a t emPora recentlY died" in met had we who Alex son ers' son g-leader, evening vesp memory of their Young in fulsome song bY in ers Fowl led D" was J. 1e the of Young PeoP rang as that c rowd with tho se working Bransfo rd" se ssions , Plannrng just wit h those wh o droPPed office swa rrned with or the outi ngs were "WeekdaYs, the w eeklY newspaper, memo rable for ManY art or while' offering a on the writing gene rous wi:t h on and to cha t going alwaYs s wa in what dial CarPentert 1n to see also very cor wa sMr. J ohn was I t nefactor Hun be L" Others H" M rs. Lhere " ld he ld. A chief he cnics" were or PJies hay rides h is ranch for and a lnum ber of Part ers, others ín the many ing Pool, swlmm Lawth Joe offering their es tate of the o were on the shadY egat ion " of the congr att racti ve homes Mrs" Ted Jones' were Mr' and ent rtm DePa High Mrs' Bernard Clintonr ilSpOnSOrS of the Senior h elPful, were most and verY active her rnother' Other teachers ' all Charles Anderson' Mrs" and Inge P. sful as with Mrs" H. nev er as suÇces was group e age good and regvLaÍ rr1î,s progra m with the colleg ago ing grouP with fairlY re8 istered in we did have but SMU students When t schoolers ers. there weren Sr the high Pa rt ies ' School and at v esp ç¡srch . fo ria Sunday at aside e t resbYte se a t t endanc was sof? Motion for Summary evening Defendant's Affidavits in Support of First Motion for Issuance of Letters andset Forthcoming Judgment - Page 62 anAmended and for bwo and Rogatory 1938, of etc" fa11 the Method ist s, BaPtists ' remember announcement s for Southern and Northern. By the next fall we had combined al-l the Presbyterian There were no campus ministers as such aarpu" -tn* work, as it has been ever since" draw to the students into their local protried churches and the time, u¡ grams " nÏn the of 1939 I took the Highland Park young peopl-e to Kerrville a New for a conference and there met Bill ?ruitt, a young bachelor preacher fronnext the married background. were ltle bírth and by tU"*i"o church, though Texan summer and my staff relationship with the Highland ?ark Church terminated. summer 'rTies and friendships have been maintained across years and distances' however. And since the Pruitts have been missionaries to the Congo, the Highland park Church has had a part of our support, we have spent considerable furlough time in Dal-las, have often worshipped and fellowshipped in the church and spoken itr"r". We and our mission work in the Congo have been the beneficiaries ofsomany that gifts and projects from individuals and groups within the Church, special in warm and a "p"ciaf Park Church Highland the wL continue to feel we belong to relationshiP.'l In 1942 Dr, DuBose was ca11ed to a church in Montgomery, Alabama; at Highpark he will always be remembered as the inspiration that resulted in the land uuifaing of the sanctuary and as a beloved and indefatigable pastor. On February 11, 1960 he died of cancer of the throat" Dr. Henry Wade DuBose left the Highland Park Presbyterian Church of Dal1as to become the minister of Trinity Presbyterian Church of Montgomery' Alabama, Dr. Donald G. Miller, the Assistant Minister continued to serve the Church while the committee selected by the congregation to seek out a new senior minlster pursued its assignment. When During Dr. DuBose's pastorate a very helpful preaching mission had been conducted in the Highland ?ark Church by Dr. Peter Marshall and this minist ry of the Word had endeared him to many of the congregation. The Comrnittee appointed to call a pastor had invited nominations from nembers of the congregation. Those who wanted Dr. Marshall were vocal and the Committee interpreted this as the leadIng of The Holy Spirit and proceeded, with the approvaL of Presbytery's Commission on the Minister and His Work, to recommend that a call be extended. Dr. Marshall lndlcated his acceptance. The Lord of The Church had other p1ans. He closes doors as well as opens them. Mrs. Peter Marshall's health was such that her husband decided that it would not be in her best interests to move to Dallas and he decided to remain in his pastorate in Washinton, D. C. ' Lamentably, factions appeared in the church" Unauthorized groups called ting their own nominees' The authorízed to noninate a minister was attempting to n atmosphere that was divisive and a e congregation" At this time Dr" Miller' r to accept a teaching ministry at Union , where he served the Church with great e was urgent need to correct the existing to Dr. Frank W. Langham to meet with the Secretary of the Southwestern Area for of our own denominabion, and for many The Thomas W. Currie Men's Bible Class" de if the Committee and the Deacons were of this meeting was nothing other than a s devoted to the reading of relevant L4 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 63 Scripture Passages' to heart-searching Head of the Church' for the lack of love of Christ. o{'n:liu::l^'l.oä:';:å :? :T:'::;il:' ;lilit;.:"i',"iåol'l':îf"ïiåll'll.;;l'"ni"' in the Bodv manifested tn: Holy Spirit wrong prayer" in knees relationtheir Then al-1 went to uitit"â"" and was the washing conf""l¡-åï""o?'*'à"g po""t" Himself in evi¿enl one u"oit'"t" Theregroup was fused to ur,¿-irt", God, i" L"fo," the ships were pouf"ä'"jra u,,o uitterne.ss, u'¿ petti,'""" "",,".,", all away of into a sPiritual unitY' to nom' ;*.1î'::t;t"'ln"t' The members of the committeethat thc out pointed rnd a un*as rt resignations. t:io:. leãuest trrat choice, capable,"r"å-rãniesentativ" was s: confidence ;;;;;: uoi" or'comPlete Thi's they agreed to do' to-""-"'"' they continu" doors as well as opens them' "i"Ïtîr"äTåi:":;" we noted that God closes church' 1::'u" r#å :l:å"ii:"i: l"::i: t Jr' Elliott' Tl:::i':iM" Dr'-witriu* rhe man was ;l:':::,:ï'î1"*;"i:T byterian Church of perienced a growth life that was notew physical church st pastorate of this in the denominatio pon Highland Park be needed to lead t and been more wonderfully ManY and great have Go9':-fulott has no way Presbyterian Church' butin inof Dr' Elliott as its minister' the surely ,nanif""iãã-lú"" "äiå"ilo" Leland Dr.El]-iottassumedthehelmofHighlandParkPresbyterianChurchin t'a"e him here ever since" own his u""n-ilttunate-to of have church i"it for a February rg44 andwe o"i rs+o when we take a u-e.soolrigr't"d McD. Kenn.ay u"c".e Assista"a ""Iaåt--ii wirl u"d.;;."K",',,=¿v rãca'l several others to in 1948. Both Dr. Elliott u¿ui"ãotã.,ät'ri-;=,n" look at the present staff uut who are no longer with us' lvilliam A" Baine came to Highland n" n-':I^:î"t:i: i: iÏ:;|:î:onî;t;'' he is at presen'Ï :";:iltå"-'t"""t'; :':"iïi: ;:'::*l:å îä":i;:ïi*;:;*;; vin Presbyterian Church' lalras;-;;"t"t of the Jort" ca again in that It was in the fall of 1950 intro to voted of its staff committee' 23 than for more Dr' Arthur V' Boand' Antonio' A its as terian church ãi s"å of the church' ' folthe pastoral work work at Highland Park' Boand was devoted in *a" reaved and new rnembers; t'" Sermons in Verse Dr. ,.., B:;*, visiting the congr-egation'.::?:;:itii.;l;T: of us are famlr u-po"t ãnd many I to retíre i:"i"::li;i'åî""ù1"0"" of st'teng 1":r'.""?î::"::1il'"?ä!üi1:îi'i:' a -tower i" Ñew órleans ut'i""u"--ruly his "'"i,Ti'lî;,1îu St. Chatrã" e"t"ue Church at the st*"rt*N"t orleans during that ?i".¿ and Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 64 serio;;;r;;i"ane the during 15 pastorate, From there (after a three-day interval) he went to St. Paul's Presbyterian Church in Houston as Supply Minister while the regular pastor recovered from a heart attack, In the fal1 of 1966 Dr. and Mrs" Boand took a trip by air around the world. A letter from Dr" Boand before he left says that "l4ost of the money for our trip was given to us by the members of the St. Charles Avenue Church in appreciation of our ministry there." And now Dr. Boand is back in Dallas where he served as Interim Minister at preston Hollow Presbyterian Church" It is hoped that he and Mrs" Boand will continue to make their home in Dallas. Edward A" Mohns came to Highland Park Church as Associate Pastor Presbyterian Church of Seattle, Washington. More about him later" from Westminster In 1954 Dr" of 1957 Mr" Robert L. Ferguson was ordained by the Dallas Presto our church as Assistant Pastor began in January of service bytery and his bulletin that announced his arrival noted that he would be fóSa" The church for his own church presented itself" He did opportunity the with us onl-y until Mr. Ferguson is presently pastor of St" of 1959n October stay, however, until In December Marks Church in Lubbock. Mr" Robert C. McGehee came to Highland Park Church in April of 1960' from a church in Louisiana, which was his first pastorate after graduation from Austin Theological Seminary" Mr. McGehee had begun a career as a physicist and was working at the Army's Redstone Arsenal near Huntsvill-e, Alabama, but he could not get away from the call to the rninistry. His wife and two daughters were mlssed as tìras Mr. McGehee when he left in July, 1963, to be pastor of Grace Presbyterian Church at Plainview, Texas. Certainly Highland Park Presbyterian Church has been fortunate in the guality of the ministers who have guided us through the years. Almost egually valuable have been the services of the women on the staff, from the many faithful secretaries to workers in every facet of activity. It would be impossible for us to recognize all of these faithful, generous women but we would be remiss indeed to 'fall to place a laurel wreath of praise on the grave of Mrs, Ralph Howe, who was for eighteen years our parish Visitor. And three of our many wonderful Directors of Religious Educatíon--now called Directors of Christian Education--have a special place, Miss Summers Tarleton carne to HPPC in October of L944; a trained worker, she was generous with herself and ready to share her e>çerience and skill with everyone" The Church Library really started in her office where she had a number of books avallable for teachers and students" She left our church in 1948 to become Professor of Religious Education at Queens Col-lege in Charlotte, North Carolina. Miss Margaret Bowen, a graduate of The General Assembly's Training School, Jolned the staff in 1949, Her experience enabled her to coordinate the entire program of religious she lrras especially effectíve ín securing and trainl ng te achers andeducation; workers for all de partments. In September, 195L, she to be Associate professor at Flora MacDonaLd ColJ-ege, at Red Springs, North Caro 1ína. e year Miss Louise McComb became our Direc'tor of Religious Educaeas that she o riginated are still an essential pa rt of our reion activities She was both an excel-lent organ)-zer and a person iLity. Among o ther things, she put together a Christian Education ed the annual e ducation dinner, startêd the Church School Council School Cabinet. In 1959 she began the basic teacher training She s ponsored the form ation of the Drama Group, now known as the 16 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 65 t Tenne ssee ' Pitteng"Ï"itill":: ?:lîi";:;t"':"i"ill:t;l'iil'"' rn 1e50' Mr' David polä"-Oi'^o;tt""" o" f.iLL"the newly createclc PresbYterian "ho""r,'ïo;;:;;; ãr t'rnitY Our Present Staff the P ast, concerned with Since we are mostlYministers a nd the Busin ess be confined to our new Pos ition in will ou r Adm staff look at the P resent ivelY t re la inistrator' a the Lay P eoPle who talented ed, render dedicat is made uP of contribut ion thes e lay Pe ople staff fice Of The raL af faLrs t ed The Business jobs for a long time.knowledge that the temPo su bordina their in ' have been should be kePt done so tn the ch is chur try the minis of m to the tea day- to-daY operation fy in the to sefve onlY in church. spiritua I affairs" rative a dminist ha ndle the to íon rives icat st Of fice staff se rvicer commun food Business e roll, To this end th to :f inancing nembershiP staff f'or Pa storaL duties" ia 1 ' deta il as it relates e to free the minist er maintenanc ask at Highland necessa Promo ting gi8 antic t Tennesse from Nashville ' Born in 1956, is PrimarilY who JanuarY t The Pe rson ' Hobin who came t ousln the Board of World MissionsMr' Hobín' R. of KYle lives, urer Park is treas assts tant f rofn the John Ho bin,still where he had been whe re his mot her, Mrs' and re ceived a B"A" degree rF; al Co11eg e Turnerville, Texas, during World War ricultur NavY Ag ne ss the in his count rY s Schoo 1 of Cornme rce and Bus La att ended John Tarleton served He is the South Texa S, Tre asury DePa rtment, Uni versitY of Texas" account ing at ed studi ?ub1ic SPe¿ king he with the U" Lat er studied course e He ì9s ietY co rresPondenc " rr¡s11sç Chu rch Busin< Account ants Soc Law t took a onal a as )rs" ratt Internati ce rtified gradua te of th e Business Adm inist and has been Church of Institute at the Watkins he by the Nationa 1 Association HPPC: Adminis t ra to rtt he came to before t ive a rch Chu were extens church service selder of the First PresbYt erian n Church of ria te Ky1 e Hobin's sbY Pre ruling and Second of the r il of Wes tern Texas' ru1 ing elder served as both deacon rved e rY S Counc 1 ater as sbYt and Pre e Hobin has se enb er of KYl McAllen' Texas, rch, ewasam chu h €XâSr our se rvice with Nashville ' Tennessee; of the Synod ofT a decade of Council e than Committ th of more rdshiP Divis ion During his Stewa rdshiP ttee of the Stewa Sub-Commi ected Cha irnan el Audit as Chairma n of the vlas gudg et and Hobin Mr' Pr esiden the L962 of n Ín he became Texas' and Cha i rma 1966 st in hea and Nort of s, of the PresbYterY Church Busi ness Admi nistrator Administ ra tors. ss ine terian Bus Church the PresbY of c iat ion children-of the Nat ional A s so Jan€r have two and his wife' he and Kyle Hobin is married and ?at, age l0' of Marsha, age L5' Pastor and M;lnister ciate Asso he attended school our P resent Mohns, t where A" from Alabama Edward Dr, in Bi rmingham, He receiv ed his B.A " degree born was the yea r befo ch ristian TeachinB' and high schoo 1 Years ' Tennessee-* Di.vinl rY itY in Cl a rksville, Bache lor of through elementa his Univers ed erían ÍeceL recerv ?resbYt Dr. Mo hns he a 1so Southwe stern where MemPhis' to narY ed Sem:i mov 1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters gica Rogatory and Forthcoming Motion for Summary Judgment - Page 66 this inst itution PresbYteria n Theolo from Louisville {egree syst em and this resPonsible f or on the WaIter Kennedy Patti.;on 'FeIlowshìp a schol.arship for post graduaite studywas prlmarll-y i,n the University of Edinbr'rrgh study Thts Greek. io"Ñ;;-i"stament at Mansfield Collegeo oxford" England. ort ulso in,cluded one term rnatrlcuLateddurÍng Easter vaca'hi"ono made an e:xtended who, iä"*"" one of a group of students tour throu$h Europe includi'ng the Holy Land and Egyph" Dr" Mohn's first pas'toraÈe included churches in Greenvi.l"le, Alabama, Mont'evallo, Benton, Haynevíl1.e and LowndesborO. His seCond pas'torate was píttsburgh, Pennsylof Church Presbyterian F.lrst to there went,from Ãiuu"*á; he Macartney" From there Dr" t{ohns ;;;i; aå Asslstant to Dr. Cl.arence Edward New Jerseyi then as pastor of in Newark, Church ?resbyterian at Ttird ""irå¿ Presbyterian church in Grand Rapids, Michigan; following that he westminster of the lvestminster Presbyterian Church of Seattle, l{ashington, He "ã.*p."t"t iame'to HPPC as Associate ?astor ln February, 1954" Minnesota" Tn I93Z Dr" Mohns married Grace Updegraff Bergen of tlinneapolis, Hoagland, R. to Laurance rhey have two children: Grace U" Mohns who is married year at Southwestern Meclical second in his is who Mohnso Bergen J]-.', ^Áa Edward Honorary Doctor of School here in Dallãs. Io L947" Dr" Mohns received the Divinily degree from Alma College, Alma, Michigan' of Pastoral The Reverend L" McD" Kennedy, Associate Pastot and Mlnis'ter distingu;ished of Câre, was born J.n Spartanburg, Sot¡th C¿¡:('llnao with a background and other a Colleget forebears,--one grandfather t¡tas a professor and pres:l"dent of fr'om degree B"A' got ir'ís was a Presbyterlan minister and edltoro MaG Kennedy 1939" in Wofford College tn 1.93? and an M"Ao frcn¡ Soq¡tbern Methodlst Unf,versity Semånary He recelved hts Bachelor of Oívi.nLty degree from Un:lon T'heolog.ical (Rlchmond) fn 1943 and hls honorary lloctor of Oivinåty degree from Mldwestern Unlverslty in Wlchl.ta Fallso Texas in 1958" He narrled Martha Elizabeth Spencer fn 1943 and they have two chÍl-dren*-Câppy (now Mrs. James l'tl' Cory) and Lisa o InstÍtute in lrlinnsboro, South Carolína, after graduatfon from wofford c\cllege¡ he was youth r''¡or:ker at H?Pc in 1938*39' TÎre next year he taught English in Spartanburg Htgh Schol"o in Spartanburg, South Carolinao leaving there to enter Unton Theologlcal Seminary" [n June, 19,t3, he enteråd the Chaplaln Corps, USNR, where be served two years at sea in the South Paciflc theater as Ctraplafn of S" S" Lurline, chartered Navy transporto In 194ó" he came to Hlghland Park Presbyterían C"hurch as Assistant Pastor, leavlni ln 1948 to become pastor of Broadmoor Presbyterian Church in Shreveport" From there, in 1952 hè accepted a call to the pastorate of Fain tlemorial Presbyterian Churcb in Wlchita Fa11s. He returned to Highland Park irr f963 as Assocl.ate Minfster for pastoral Care" Dro Kennedy taught ln Mount Zion Dr" Kennedy's list of activities is impressive; membership on the boa rds of T.M .C.4" n Salvation Army, U.S"O" and Wichita County LegaL Aid Society, 1n lllchit a Falls; membership {n N.W" Texas Area Council, Boy Scouts of ^America ' d Fi¡nd Board of Trustees and Budget Committee , member of Wlchåta Falls of Chu¡ches, member (and past president) of Wtct¡ita Fal:ls Ministerial rM enber of Presbytery's C¡runcll {n the Presbytery of Central Texas' at rrnan of the Board of Trustees of Mo-Ranch Presbyterlan Assenblyo Pas t tor of Red River pr esbyteryo Past Moderator of Dallas Presbytery, Past tor of Ce ntral Texas Presbytery" He is a member of the Board of Trustees Retreat Assocíation and Montreat Colle ge and at Present President rtan Pastors Associatlon of Da11as" verend Robert Earl pr:lce Assocf.ate Pastor and Mi.nister <lf Evangeiism, , Cllfton" Texas but came to Dallas i,n infancy and was reared here" Rosenon\ Elementary Schoo 1 and Sunset High School" Between gradr;rat .Lon 18 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 67 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 68 1q Thp quali'bi of the mr¡sic in thj.s church over the years has been due in no small ineàs'rre to the presence of Organist Sarn R. Parker, who cornpJ.eted twentytwo years of service in this capacity on Febiuary 1" Havíng served as assistant organist for a few nonths, he came at the first of February in 1946 to nl1y for one month as organisto He has been absent for only two Sundays other thanþcheduLed r¡acations in the whole period. He spends a mínimum of 8 to 10 hoi ç a week ín practice at the organo Mro ?arker plays for all regular services !It- worship o:f the congregation and for practicalLy aLt weddings, as well as for services of baptism and for funerals. Sam Parker is married and he and his wife, Emma Lou, have two sons - Roland and Paul. The clímax of this survey of the staff at HPPC is, of counse, a summary of the career of our Senior Minister, William M" Elliott, Jr. He was born in Charlestown, Indiana, the son of a Presbyterian miníster, attended hígh school in CLovis, New Mexico, and received his B. A. degree from Park College in parkville, Missouri" His B" D" degree was earned at Presbyterian TheologicaL Seminary in Loui.sville, Kentucky. From the University of EdÍnburgh in Scotland he received his Ph.Do Dro Etl-iott is the recipient of three honorary degrees: from Dar¡idson College an Honorary D.D.; from ?ark College an Honorary L"HoDu, and fron Austin ColJ-ege an Honorary Litt. D. Ordained a Presbyterian rninister in J-9300 Dr. -Ellíott was first an instructor in Homiletics and Church history at the Presbyterian Seminary in Louisville" Thence he went to KnoxviJ-le, Tennes-see as pastor of Fi.fth A'venue Presbyterian Church, from l-930-35. fn 1935 he became pastor of Druid Hills Presbyterian Church, where he served for nine yearso He came to HP'P() in February, L944, and we are most happy that he is stil1 wi.th us" Dr" Elliott is the author of six books of sermons: "Coming to Terms with Lifer'r "For the Living of These Daysr" "Lift High That Banneri'e reTwo Sonsr" "Power to Master Lifer" and 'The Cure for Anxietyo" He has delivered radío addresses under sponsorship of the NationaL Council of Churches, and for the Protestant Hour. He has preached at several conference centers--Montrea'h, Massanetta Springs, Va., Chataugua, No Yo--and at a number of theologÍ.ca1 seminariesa He has spoken in the following colleges and universities: lVashington and Lee University, Duke University, Agnes Scott ColLege, Maryville College, University of Georgia, Southern Methodist Uníversity, Vanderbilt University, Austin College, A"-&M. College of Texas, Davidson College, Womancs College of North Carolina, ana the University of Tennessee" to the Far East for the Board of World on which he served for twenty-six yearso months surveying mission work in China, 1957 he made a second trip to the Far eae Japan and Taíwan" He has traveled e and the British Isles" .:. ?:: as Moderator of the General Assembly of listed in WHO'S WHO in America. He is e three chiLdren: Joseph McAfee, Carol Jeannette Louise (Mrs" James D" Logan), :i :'. 20 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 69 CHA TXR IV ON SUNDAY WHAT }IA?PENS ?a rk was comPresbYterra n Church On MaY 2, Hígh land Schoo 1" organ ization of íon of a SundaYformed' Even be fore the committ ee s organîzaï the r fo were taken s e were ss pleted, stePs House' c1a School org anîzation' ?a rk CommunitY W' A" 1926, at the sig hlandements ma de for a Perma nent Sunday School and Mr" ay Sund the attang of apPointed, a nd suPerintenden t was the first ems We R" Sam Mr. t suPerintendent' Fosdick was a ssistan served as superinmen who have dedicated llst of the The following ís a ch School: tendents of the Chur Ed Agnew Jr Sam R" Weems Joe Lawther R" D. CamPb e11 E. G" Mugford Adair M. M cVeigh, Robert A" Wilson V ern K" Benson Wm. H, E" Robertson DYer Ray Matson John S. Fu 11e r Melvin Moore AJ- B rookin N' Ed W, Lehde H" Wadl-eY L" (8i11 ) Johnson Wm" J, Hils eweck .Aus tin B" Watson SuPe St" PeÜero Present rintendent the Fe L926 ' endents in the soring of o f ttre tt the suPerint rl-nhave served wi who Since the organizat:lon suPe lvomen nd a men dep artmental ries , trea surers, our Church Schoo 1 Into have been manY wonderful creta se le have help ed buíld as assistant suPe rintendents, Church U" S" PeoP These chers. t endents, and tea in the whole Asse mblY o;f the Pre sbYter:ian membero ne of the finest of oPeration' the at date Ye comPlete that af't er almost one Church Schoo 1 enrollment a t On AP ril 1- , Lg27 , The grown to 239' shiP of the Church had )'8 was 310. Augus t, L2, 19 SundaY, on chaPel was tat ion to held in our ownThe formal opening and Presen The fírst service r offLcîating' SePtember 30 , t928. with Dr. W" A, Alexande ed on SundaY, occurr of the congr egation the membership t'(' t93l' 3L, MaY on The e ye ars of ope ration' enrollment of 795. School anc After almost five rch Church chu a grown to 68 3, with t pace with the growth of the had Church the church Pla nt has kep pa nsion of the ín chu rch school" main fa ctorå the of one been s Lea of thi s church ha inued suPPort ' chu The mínisteria 1 staff and ch urch school' Their cont ram of our our church educ ational Prog edtca' the of cess the exPansion ofgtaye the suc the Christian for Also rs growth" and 1 Leade shiP, work siasm of our phenomena cated Prof essional has sPa rked the enthuchu rch has be en blessed with dediorigina I Part- b ime DLtecl the Frorn our Míni ste tion Pro ê ram of and s ta ff of two carrY out our Programô Education build lan n the to Plant toP peoPle i to our Present Chr ist the had Education ve ha ious we of Retig of Chris tian Education' and two D ire ctors fie 1d " Church Schoo I c d Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 70 2L It is a pleasure to list below the directors who have served so faithfuIly in our church: Mrs. Frank (Ruttr Parks) Taylor Mrs. Wm. (Virginia Gray) Pruitt Mrs. A. J. (Virginia Castleman) Van Pufflen Mrs. Joe T. (Aliverre Anrterson) Wa il es Miss Summers Tarlton Miss Ma rg aret Bowen nL } Mis s Louise McComb Mrs. Charles Young Mrs. Stewart (June Deicke) Rogers I{fùv J- l{a¡.teÊ (nuuy Brock) Dickson Mrs. R. B. (Margaret Cowan) Brannôn Mrs. Robert (8e11 peck) Saunders I Youth Workers Dr. L. McD. Kennedy David Pittinger Ross Kervin Our present Christian Education staff includes the following: Rev. Farles J. McDaniel, Associate Pastor and Minister of Education; Rev. John M. McCoy, Jr.; Assistant ?astor and Youth Director; Mrs. Byron Kennedy, Adult Dlrector; Míss Angela Brown, Children?s Director" Space will not permit a complete detail of the growth of our church school but it will be interesting to set out the growth on five-year intervals: 1935--1,467 1940--1,608 1945--1,793 1950--2,833 members members members members 1955--3,336 1960--3,682 1965--3,746 members members members In the early fifties, the enrollment and attendance started increasing very rapidly, as you can see in the table above, especial-ly in the children's division. Bvery room became so over-crowded that it became impossible to present an effectlve teaching and learning programo rn many rooms, which were designed to accommodate a maximum of 20 children, 35 to 40 were crowded into space much too sma I 1. ul study, the only solution that could ne at 9:30 o'clock and the other at ere encountered, the greatest being to p. To give the idea an opportunity to f the adult classes to change their ge thern to enroll their children in It was thus established in 1954. cent were willing to change hours; this, e the over-crowded conditions very the youth department at this time. A with splitting the youth program, at 9:30 and the 10th, l1th, and L2th This permitted the use of the space lly used at both hours. s accepted and dual sessions are now youth, and adult. While the attendance ock sessions have gained in favor e is running at approximately 60 per 22 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 71 sessions' starting of dual teaching and tha t P roblem al admi nìstrative required eac hl a ddit ion the Anothe r tremendous of workers of r ining tra a ent and the numbe sessro ns and wa s the enlistrn det e rmined that dual a nfl quicklY thout í W was teachin9 frrl needs. meaning pe rsonnel ' It former a the serva nrt was double re s ent facilii:ies 're due the f aithful our P SundaY morn ing with a r even e and enrolle d ManY thanks availabl s balanced enro l1ment inoPerative ' be would to ma ke the iroolservice learning Prog ramwiLlinglY offered session' of our Lord who in the l1: O0 o'clock chu rch sch which is Cu rriculum, their children Life s a challenge new Co venant cur rículurn i seriouslY aPProved th e This ion Sess our take s the church" In 1963 al lageg rouPsrdini n a teaching minis t rY that with used beíng now, to move fo rwa in our time" to the who le church o f the chu rch of orrr church time the educat ional task Picture over-a11 the at the s tuclY? At brieflY closer to looke<l for e hav Now that we few sPe cial Phases ssed children aged one Year a out 1e first sing the 11 encomPa school, sha 11 we move d into d the Cradle Rosup end ent. We organize can be foun d rint was e rd reco was no our church Brooks Although W" R' Sunday) " o f. L928" (more on East er four Years and Mrs. 1n the summer twentY building a round wing of our new E' the a tt endance being emember r some !928' Mrs" Joe nowr October, leave In r ea g rowth. a two-Y had a continuous ed sixteen Ye ars, with intendent ' It serv The Cra d1e Ro1l super ende nt and a cting Lawt her ma de suPerint Grang er became E. .rea rs bu t Mrs" c. La wther was Mrs. these when on during , 35-37 of absence, 19 the f ine workersdu t ies. In th e'earlY t hirties, all e nam to b1e their is imPossi manY mot hers.tt f aithful in a 11 the class, with in sent recalls tt¡¡sY w€re had ninetY Pre so cal led all the Easter SundaY' we mothersr Di re ctor for a class of Pres bv terY's need the Majors, t c" Cu rrie Mrs. Lawther fel s was otganLz ed' Mrs" L" then MTS " Tom Class" inning. beg a clas Bible class in the Wom ents mothers ou t and ion , taugh t thecl ass later me rged with the Educat of Religiousre gtLat teacher' The 48" Cradle Roll was became the the in nce the average attenda thirties' middl'e ?'-Age 3, with the In and NurserY 2 l*Age Then in became NurserY I suP erl nì; endents " Rol as Cradle erving Sunda y1n In 1945 o t he Sr. and M rs. ?at Weaver s On the firsb started" Mrs. HarrY Blocker ' s of SundaY School were session two L was 262" 1954, the nur serY enrollnen the of aB e " A class 966, 1 August, two Y until ool children t i,on. AI I t o church sch allY for instruc"¿¡s start not do Now children is h eld Periodic two-Ye ar-olds eq uipPed nurserY' for Pare nts ofkePt well her our in are 6u¡ çþurch until irt under two of work e th all d in st arteó e and intereste see manY of the chil-d ren who as offLcers to Mrs. La wther, activ chrrrch rr1¡ i s thrilling serv ing in our rec ent death said: five or fortY Years a go, now our school thirtY-wo rke rs. tt meeting a and still were we and teachers the while church school, A" H" Es tes" Soon after our of and artment The PrinarY DeP n under the 1 ea dershiP of Mrs. became SuPerintend ent Feild bega rge l4rs. Geo the High School, wa s completed, building church new years' c oo P ianist, no served for seven eoL chers, tea hom four the She visi ted first SundaY sh erefound be Ioîg c ru1 t helPers' OnM rs" Feild's to who did not was milies task fa irst f tea cin:n6 cane from So, her w ith the the PUP ils helP sec reta rY " of to many e too' sinc the ir mothers, everY child' and F eild en listed Mrs" Defendant's in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 72 church' to ourAffidavits develoPed wi.th 2j of the stanchest members of our church came in from this beginning" Mrs. Srootin N. Wadley was one of those mothers who responded, one who has worked continuously in the Primary Department since then, for 36 years" Some The custom of havíng a n ^jrir,, of the teachers in the homes once a month been the began at the start" Througho"Þl ttr" years this has continued and has other" The each for felt teachers have Primary the ,"Zr"t of the closeness that material primarily providing the with concerned were i¡-."t teachers' meetings children essentiats. One of the first projects was to secure a driveway so the donated Primary Each teacher church. of the doorway coufd get into the east ion"y ãnd solicited funds, and raised enough money to build the east driveway that remained until the remodeling in 1965' During the winter the bare floor was cold and the teachers decided to earn the money to secure a carpet for the Primary room" They gave a benefit luncheon ,l tnu nåme of Mrs. James Webster (Mrs, Feil-d's mother) on Potomac and GolfatDrive. 31 The teachers prepared the food, and served a seated luncheon to L44 wonene was carpet the added, churches tables. With donations from friends from other finaLly a reality" They secured the curtains for the room and were inspired to take on other projects until Dr. Currie objected, The church had inaugurated a policy of limiting its programs and energies to spiritual concerns. So, the teacher's meetings through the years were the occasion for the planning of the programs for each Sunday and for sharing ideas, experience and inspiration. The programs were planned by a democratic process with everyone taking part and thus, the various talents of all the helpers were utilízed. fhis maáe for a flexibility and a growth by sharing that enriched the workers' experience as well as the children's. Mrs. Feild summed this up when she said, "Those seven years working for the Lord with wonderful friends were the best years of my life.t? Many of us who taught in the Primary Department agree with hero One of the unforgettable persons in the early years of the Primary Department was Madame Mathilãe Zeek, a teacher of French whose son was head of the French Department of S.l!1"U. She was one of the original four Primary teachers and continued in the Department until she moved away from Dallas, advanced in age but young in spirit. Every Christmas she told the s tory of the three Wise Men corning to Bethlehem, made even more interesting with real camel bells from the Holy Land and with vivid impressions of her own visib there, She always taught a class of boys only. And with each class a miracle occurred. The r*iggling, unmanageable boys became gentlemen. There was magic in her gentle dignity and her beautiful nanners. intendent" She stressed our need to nd since the Highland Park Methodist with their leaders to study and plan orn both churches had a joint meeting and was during this time that training prothe fa11 professi.onal leaders in Prínary hers, These courses with outsi¿e in, when Miss Louise McComb, our own er the training program of all our Church In 1941 Mrs Willíam M. McVeigh, Jr" assumed leadership of the Primary Duri ng this period the enrollment grew to 120 chiLdren with twelve r9 and 1¡5 les in that one room. With the Primary goal of experiencered teaching, this truly was a challenge" I\4rs" McVeigh met it first by pa rtm ent. 24 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 73 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 74 )< ptogram. I final-ly real-'ized he had a homemade ¡:adio a'nd was b,uned in; and this was before you could buy these pocket-size radios. There have been ynoments when bhe entire class would get 'out of hand'and then f-o bring ùhemoback'to the purpose of the morning, each, in turn was requested t,t give a sentence prayet:" After that the lesson would and couLd resume.eu Píoneer activities have not been confined to the classroom. Among the many outside events were bus trips to Itasca Home for Chil"dren, skating parties wi,th picnic 1unch, swimming parties at private pools and picnic lr-¡nch, horseback riding, trips to water filtration plant and visits to church camp wi,th games and picnics. "it"" Mr, Kirven te1ls two stories about two former students: "ll4oneta Speaker, of Dr" C. E" Prince (Jack) is doing missionary work in Taejon, k.r"u.' wife now On one of our Pioneer bus trips while returning home from Itasca she was very tired and took a short nap. The other girls then took lipstick and marked her face all over like an Indian. She pretended not to awaken" When time came to unload at the church she thought this action was funny and took no offense. This was the kind of a gírl who would decide to be a missionary"', He recalls a very special trip when he took several Pioneer boys on a fast trip out of state with Mr. Wm. Hilseweck to his ranch. Among the boys was John M" McCoy, Jr. "We arrived late in the evening and all of us moved into a large one room log cabin. Mr" Hilseweck had us sitting ar:ound the room on bunks and chai¡s and was about to give instructi.ons for the next day's activities when a rifle John was holding went off and fíred through the ceiling" After a period of silence, the first instruction was on how to handle a rifle safely"" As you know John is now Rev. John M. McCoy, Jr., who had recently joined our church staff as asslstant pastor to work especially with the young people. Mr. Kirven says "Enough cannot be said about the importance of parents keeping their children regularly in Sunday School so that it becomes a part of their very life and later the life of their own children's children.'o He makes a canvincing case when he points to many of his former pupils: ,rGeorge Tinkle, Jr.,,, be the result of growíng up in the b of the Sunday School, a deacon, and in this church. These young mothers d the young men become our teachers, Paul Donaldson, always an adorable girl, uabourg in Africa. Harry Knight can be im l,t¡iesner is lead-teaching in the Anderson, is raising her family in the e work" Will C. Jones III, a talented church for many years, was one of our ve up his profeésion of law and our ow Rev. hri1l Jones and has his own not have to look beyond his own famil y to prove his point: the Donna, now Mrs. David N. Trent, is a ctive with her family in 1 and circle. Ross B. Kirven, the son, after having attended his degree in business administra tion, was very involved in mp work, reaching his own decision that he wanted to becorne a 1if e work. He attended seminary and now is Reverend Ro-ss Kirven rch '"*l"T,l'ï; i:i;iJ:,;:llii,:,,;:;ll*.i:;.äi:, l;:.3.ï":f".;f",;l",il,ll,l,,"o 26 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 75 ung people g rouP of Yo thls lrom re owth in gr still to secu and their con tinuing I resPon is and s ibil!tY was 1 the Chu rch Schoo to J esus Christ ' the Y ea rs ,ln div i dua ea ch lives and eir th of and acliv :it:ies commi tme nt ra cï er" Through cha ests inter add i nterest, Ch ristian th roughout all âfûr Ie ad ,in Ptayel and knowledg e and stressed are and deve loPnent to take a Pa rt on the Progr the m ee t ings " fellowshiP to member t s urged disconbinued warm' friendlY a ? es were wcrship s e rv:ic evening vqsPers" vening SundaY of SundaY al am th Progr s of varied ActuallY the convention emPhasize t he You peoPle with Pr og ran to order youth' in Hi gh Schoo I in APril of 19 45 provided our younB unior J have The separatqlY; t services have c ho sen. grou ps mee Th ese evening bheY them selves Youngi Adult dePendisg h and whic ac tivities, the College follows a worshiP s e rvice t of a church School High ' recedes o r at t he home tho se in Senior open house Cur rie Hall P in an en supper Oft red. a light beíng conside on which group is serv ice at t he church' the rk PresbYt e r'ian member follows High land Pa in s high portunit i' s 5 the senior of ion to the oP ve met t(,life addit the In In th e sixtiesin s tudY and fel lowshiP' the Church, seni-o rs ha prog of sPecial Y early in Chur ch has c entered SundaY morning s chool and treats' re fl,rgyle, at prog rarlr offe re d through the Mo-Ranch, CamP vesper ro led night ay travel gethe r in the Sund study g roups, and h ave afternoon 11 in sma tearn tea Youth Di rector, Mont reat. t he cl'ass Peck' grade th lf eadershiP of Belle oP tícnal hwe I an to the and s attemf)t s under an grade cla You rn ïn L962, to elfth eaks tw hohe chu in the Bible rom their away ing was initiated Ro bert McAf ee Brownts The co lege e g seniors or was formed using graduatin the entire ogla helP better Prepare riculum, r Cu Life the dis Co venant was Placed on shared adv ent of the the EmPhasis with d" rs In 1963 leade lized and reorganize rsta and their adult th the You for Youth was revita both session' To e unde whic h studY in t ra inrsnip the hing de a ing teac I imP lement meth od of attended and ts adul npl anning learn ing, Youth and l, spons ibilitY i to Pr esbYterY leve roach the aPP at new and bett e r the local c hurch exists b e s in the enthus ia sm and e oPPo rtunit i t the church families tha he their and church to the t the Youth from to te moved was demonstra 1963 us ing To st¡mme r of SundaY v espers the the in led a Bible study building' a 1e d the chu rch Rev" John McCoY teL Sanders year Dan Rev. JimmY speakers we members " esusl. Th e following special 1 Abou tJ time' cia to S some of Fron time What 's So es Houck were Franc espe r program. ev Mrs. es, tudY Elliott , Rev" Da n Hugh v espe rs ; Dr" va rious t i'm "sbyM grouP s led at y andf sma 1l study fo r Bible stud individual chool s after Meanwhile, rs me t ith. A rthur C' Flinde the ch rist ian fa to late re McCoY and Mrs" a¡ as theY ung PeoP Le of se cular mater ials ga ve our Yo which ittees o f Youth in th e fall andtosPring recre ate. Comm ms of the tel,te Retreats wer e held and chr and Progra to re-e'valuate t occasion t o studY,leaders P lanned t he schedulesr essed the r el evance of the their st and youth wiih with their a dult Y ou Confo rm?tt shiPs of the "Must itled t relation was nal retreat int erperso faith in th e day"a to-day nd their f amilies " eaclt at l'1o-Ra ¡¡çþ in their teachers ' s I workshop and s at confe renc e at Montre by the attended uth Conference of ions Yo Miss Groups earned ted in the World Montreat w ere to p atiui-ciPa trr P many 1964 A1so, fund s for the t964" Some of thebulb s ale" light ing agers in a Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 76 27 young people Count Down, an annual series of meetings for our youth and t'Haptt Brahams, begun in t964 wiiïh Rev" was churches, f rom other Presbyterian Other activities ir, ¿rr¿r"* Edington, ¿nd Rev. Donn Moomaw as the speakers. publishing of the t'Churchwere experiences the learning and lii"ri"g fellowship youth, the championship basket,orrr.," a newspaper about the activities of our parties and other recreaskating Flinders, Arthur C. Mr. by lalL team coached tional actívities ' During the forty years that have passed since our church was founded, i.our adult members" creasing "mpt,usis has been placed on Christian education forLife Covenant Curriculum, but the adopted session the before even This was true In the more program trend apparent" makes this this study under tiã i"t"n"ive glimpse yorr get a classes will schooL church adult of the ioifã"ing chronicles is oi-tf," mãny ana various groups through which Christian edtlcation for adults channeled in Highland Park Presbyterian Church' The Tom Currie Men's Bibte Class There is considerable doubt that the Tom Currie Men's Bible Class had an coming organized predecessor. Many who were in the church pr:ior to Dr. Currie's while c1ass, organízed of an no recollection had Several have been interviewed. be safely may It Lewis Carpenter. by Mr. group taught small a a few remembered said that the Currie Class as we know it was organized by the man whose name it bea rs. The Reverend Thomas White Currie came to the Highland Park Presbyterian Church as a part time supply minister on January L4, L933 and remained for five years. He retained his position as President of the Austin Presbyterian Theological Seminary at Austin, Texas, coming to us each week for a long weekend only. There can be no question but what the burden of this sacrificial schedule shortened the life of this consecrated Christian" after his arrival in Dallas Dr, Currie began teaching a men's Bible the members of which promptly gave it its present name. Soon ', .class, Dr. Currie was a born BibLe teacher and his beautiful Christian character his teaching. He was not concerned with material things. He called us sinners "saints," going back to early Christian history. He often, as he talked, held in his hand a book which he had found good and urged us to read" llis style, which was earnestly conversational, touched his hearers deeply" We all felt the rare privilege of hearing and knowing him, and returned his love" He always used a blackboard, ancl the one used on his last appearance here has .been preserved. In large letters appears the word "LOVE." shone through y into a large one" A picture hangs in mbers, but of course this inclu-ded onJ-y arture the attendance dwindled" However, w and the current roster shows the names The ç.1q ss has always leadership of Earl 8on the Curr ie Chorus been a singing class, and r;nder the was formed early in its history. An aid to the class s is the "Conscience Fund Plate'r which requires each member to deposit an amoun t which he would have contributed had he not been previously 2B Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 77 has Comb' " which Cu¡rie e "Th roster named aî anntJa I PaP er adoPt ed a weekly inceP t.ion of the class aw s the 1948 In 1945 regularlY ever since. been Publishe d .t.h e adoPtion ofab of the member shiP. and sma i.L large lishment in many ProJ ects was the estab ostered f has rtant Thomas White The class mos t imPo mo re of lhe one t but the or is 500 Home Past and at the I tasca through an annual gift of $1' l1 teache rs of the classrheld annuall rofa r 1950, ctures I Fund, in hono sponso rasef ies of le s to be known is to Texa Currie TeacherspuMemoria rpose of the Fund ca1 SeminarY at Austln, stentlY throup resent. The consl has an Theologi Class sbyteri Pre classes Currie aL the Austin Lectures.tt The to o ther depa rtmen ts and Currie White her aid "The Th omas teach ers and ot the Yea rs furnished t in this and was kep the Chu rch School' class the of es of info rma t ion Pre sident first sourc e th other was Mr. J oe Lawther The ros ters of the class and the Years of their ins ta Li-j,l L942. office with po sition unt succ essors in Lawther's Mr" re veal that Muse ments were as follows: McGi ltr ivraY 19 56 lein Breck O. Sr' iam lllill Storey' s7 Boude L9 Lg42 1958 John Sullivan 1943) Ted Ma loY Montgomery 19 59 t944( l\J. Ray Lrrcia n Touchstone L9 60 194s) W. l{agner MYers 19ó1 John ter 1946( R'aYmo nd M.Moss Cole 1962- Ches Fisher tg47 Harold D. 19ô3 Joe N" M. Bell 1948) Jackson r1 L964 Rode ric Kidd 1949( Ea Frank T{illiams C. 1965 Dr' les f950 Da n Johns J. Fulghan Raw R. Lg66 195r J" e E. SeaY Jackson N. Lg6'7 Ear I Lg52 Georg H" Benjamin 1953 Alfre d'L. Neal 1954 James (8i11) Johnson taught bY 1955 H" L. the class wa s staff wa arture deP 5 a teaching ars after Dr" Currie's MYers' In 194 r1 A. Brown and Fo r seve raL Ye RaYmo nd M. Ea Mr' and er s, Mr. Mr. Lewi s T. Carpent of two dis tingui shed lawYer John M' l,¡i lliams' r etired, oxganized consisting and two ministers, ReverendB ible SocietY' By r94 9, Mr. Bick ' Langham' of the Ame rican 1o ss of Mr' Mr. John H. Bickett the to fered W' suf dded Frank had a the class standi ng lawYer, h ad been and Revere nd Dallas' m fro moved d out WT lliams ha Carl ton Winn, another by death, and Mr. re,d SocietY requi th e staff. ble Bi th e American Vlr" Vlr" Brown and to m's Posi tion with ined Langha njo Mr' Jorda In 1960, Passed Georg e W' ofM r. Winn' whoar Chi cago and Mr. loss L965' the his removal to1965, the cla ss mourned taught for most of the Ye with th eth On Ma rch 26 ' Proctor and ÌÁr. Jordan' rice and William H. o f Mr. Brown P fewa rd. Reverend consists of teachers L" McD" KennedYr Revere nd R, Earl p resent sta î.f in turn bY Dr' p lace filled J. Garrison, Jr" Re verend P. Decembe The ss Highlander Cla orga ntzed a srnall B Pistor The Pis He rnan and Vir8lnia,, Iota Sigma Cla s s.tt C' L934, ear name scatCê ¡ In the Y s elected the tea chers were and te which and les ce couP spa young married esidents. Classroom from u íme to time tpr firs corner the to d name corner were forced to move from was Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 78 the class 29 often" The class, bherefore, had some difficulfy in making much progress for a year or two" Conditions improved somewhat i.n about Lg36 when a permanent meeting room was secu-red in one of the temporary buildings on the church property, and when the Reverend J. Ludwell Davis was able to act as teacher for a period of several months. By the time Dr. Davis resigned in 1932 the class had made substantial progress. changed The name was changed in L937 to "The Highland Couptr-es Class." After Rev" Davis left Highland Park, Mr, Ray Matson, who had come from Geo¡gia Tech to join the Engineering Faculty ab SMU' became the new teacher and served until some time Ln 7939. By this time the class had grown and there was an enrollment of over 100 with weekly attendance of 65 to 75 members" Dr" Hubert Hopper came to Highland Park as assistant to Dr, Dubose and he was secured to teach the class. He continued until he accepted a pastorate elsewhere ín L94L. The year 1941 saw other major changes" A new constitution and by-laws was adopted and the name 'rThe Couples Class of the Highland Park Presbyterian Church" llas made official, In September of that yearthe new sanctuary was completed and short1y thereafter the class began meeting in the bal-cony of the sanctuary. Dr" Donald Miller became Assistant Pastor and the class was fortunate in securing him as teacher" It was during this period that the class began to contribute money for and to carry out special benevolent projects. One of the early efforts was the assistance given to Richard Overtutf, an underprivileged child who needed both medical and educational he1p. Later when the Reverend H. C" Foster was incapaci' tated by polio, the class contribrrted to a fund in his behalf and arranged for a mechanical lift which greatly helped in his care" After Dr. MiLler resigned in L943, several teachers filled in for a while. : Among these was Harry Blocker who became the regular teacher in 1944. In 194g ; the class had moved to Alexander ChapeJ-. Mr" Blocker taught the class for nine ,:t : years until early in 1954 when he requested that he be given some assistance. A panel of teachers was sel-ected with one person teaching one sunday each month. ' ' i "commlttee of the ctasÁ officers" Ttrey have provided a number of special series of studies of the Bible and of Church History. of space prevents the listi ng of most of the names and the dates that Pa¡t of the class hist ory. Most of these are recorded in a compilation by Bi,tl a nd Doris Buschhorn whi ch was included with the Class Roster of t963-64" aders may wish to refe r to this publication for further detail. Even a sket ch such as this wo uld be incomplete without mention of some of the arJot àcti vities and accompl ishments of the past years. are Lack a the cla'ss grew in numbers and the Church School s upport was included in budget, the class has been able to expand its b enevolent projects. r of yea rs a regular monthly check has been given to the William F, Prui tt Fund which the pruitts have used in helping 1oca1 churches and als o in advancing the educationaL opportunities of some of the e students A monthly check has also gone to the Goodland Home and Hugo, Oklah oma. The class assumed a ma jor share in financing of F9 fo r the Pruitt boys at Austin Col1e ge which has been a six or program More recently the class has been able to send substantial the Tae Jon Christian Colle ge in Taejon, Korea, and also the the presHospita I of Dallas. These have been the major items but there have 30 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 79 gifts to local charita been, from Year to Year, special Christmas projects with organizations " L954 and continueö The Highland Diggers Garden Club was orga,ti'zed in April to be a satiãfying activity o;f many of ihe women of the class" activity, The Highland Park Presbyterian Bowling Leag'ue, while not a class Class" finds a Large percentage of its r"rb"t" to ãe from The Highlander group" rn the beThe same is true for the Highland Swingers sQrJâre dance C1ass" ginning this organízati.on drew moit of its members from The Highlander new several iite"i!", the Highland Swingers have also provided the class with members, Several socia Christian Fellowship has been a major activity over the years" almost trabecome events are held each year. The annual Christmas open house has a covered possibly ditional. Usrrally there is also a picníc, a garden patty and dish or catered dinner" I I 1953 Dan and Mildred SheffieLd which was called I'The Coupler." others In and publication continues to this date a lander" in 1963. This was because of th time to denote that the membership inclu of the Cu The class is now meeting in the Youth Chapel- on the second floor Life covenant building and has just finished the first two years of study of the Curriculum. A list of the past presidents may be found in the Appendix" Women's Bibl-e Class The lriomen's Bible Class was organized about 1938, when Dr, DuBose was Covenant minister. The International Sunday School lessons were studied until the firSt was Johnson Life Curriculum was taken up a few years ago and Mrs' Neil Greef,, l"lrs. curriculum, Life teacher of the class. Since the change to covenant teachers. Mrs" Way, Mrs. super and MrS" Black serve as regular one of the earliest projects of the class was the sale of paper napkins continuirtg through Mrs. McAlpine, our missionary in Japan, beginning in 1950 and nine proassisted Fr¡nd Napkin Paper to the present time; and in 1963 alone the jects in the building of churches irr Japan. Another class endeavor was in the form of Friendship Day, or:Lginated by Mrs. Howland Buttler, beginning in 1956 and continuing until 1965" Friendship ttaby garDay consisted of members meeting in fellowship and making and sending ments, hospital gowns, shirts and blankets to Japan and Africa' For many yearsthe class has helped the Leprosy Mission with into a piggy bank, averaging about $60"00 a year. money put Also for many years the class sponsored a student at Itasca Presbyterian Cl.lildren's llome and another at Pan Ameri,can, and the past year gave $tOO"0O ear:h to rtasca children's Home, Pan American, Presbyterian vil-lage, and the Itomen of church birthday offering" All through the years, br-lt particuLarLy at christmas 31 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 80 needy with gifts, anrJ memoria[s are always e familY tíe' Edith Pattee Class rl'bon, who was at that time Direcbor of' ass for younger mothers who wer:e jusr rch School and di.d not want Ùo be eoo tar ng in the nursery w:ith their chíldren, the teachers. ín Miss M. Pattee was asked to organize and teach such a classava:ilable be the nursery where bhe mothers would Tarlton,s office just adjoining Six or seven came to the first session, not them. nãeded in case their chii¿ren because they had enjoyed watching the children and visiting too enthusiasticallyåut each Sunday two or three more came, until finalLy the among themselves. the class moved into one of Ëhe transce{tîs rtf otíginaL quarters were outgrown and the sanctuarY. 'Mothers class" then Mrs, Austin watson recalls that "we were known as the an.' From the very beginning we decided cíaL affair for these were busy young limited our social events to two--a in the faLL" We have followed this Mrs" JameS o" two lovely events' At consequently, all the members look forward to these and amusíng book relight gives a the luncheon in the spring, Mrs. Pattee always been there" having for view, which makes each one go away feeling much happier *'coffee" ín the The only time the class spends money on itself ;is for the and hhe entire usually catered fall given in honQr of the new officers. This is invited" class enroLlment, plus the ministers' wives, are as a teacher, Naturall-y, the class has always been very proud of Mrs. Pat'tee In demand" 'l-953, she much in a Bible Study leader and also as a úook reviewer I'Learning rn Live"" to made her debut on television on a panel program called had always she appearances' spíte of her many speaking engagqmãnts ana ietevision our to lro-bl9rns but for "lÍstening time for the class--time not only for teaching, of the and counseling with us whenever we needed heLp." On the tenth anniversary l¡língs' on EagLe's book, the class, as a special treat, Mrs. Pattee reviewed death of one The year 1959 was a year of sorrow for the class*-thetragic and the sudden her, knew who by aLt of the past presidents, Min Duckworth, loved the class As always, member" loyal death of Mary Louise Bostick, a devotåd anct families' these of members responded with love and service to the for funds to During the year 1960-6r, Mrs. ¡9. M. Elliott, Jr" made a plea to- be be sent to Millicånt Honeycuti in Taãjon, Korea' The class was delighted more money for able to contribute to such a worthy "ã,r"å; and in order to have This such charitable projects, Eloise eårton offered to print the yearbooks" was a true labor of love. brunch honoring Several unusual things happened this year" Hostess for the however she the new officers, Pauline Ha1l, was suddenLy rushed to the hospital; was held patt'y recoyerçd quickly once bhe event was overj In September an ext¡'a colored at the home of the John McCoys, honoring the husbands" The beautif'ul '.3 ¿ Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 81 by Lucirle and narrated winn Carlton ,s European tripr shown by Winn the of S lides long remembered" 'Io cel'ebrate the Winn , will be Year" lhat was Sunday on tha t daY" It birthday ' c ame there be ee's to Patt of Mrs" copy a president April 9 ' her wìth resented aske d each Past P resident class occasion, the P f1s e fo r lvlrs " Pattee and the the Press' a wonderful surp Tes tament, whi ch was jus t off much Augu st for a the English New o ff .fulY and the that take sugg ested that Mrs' ?attee Edu cat ion, were rs was orde talent Rel-igious Doctor's Rea I r of Louis e t,{cComb, Directo during these two months' hs" ne eded rest " lessons summer mont the class gi ve the inued for the mem bers of cont been has P lan The most lrnPort':nt unc overed and this P rojects. many ken | LI Tr¡r'c lass has underta at the Chi ldrr.ln 'ì the vears the iudy Pel:er- ',,¡ Through sponsors iUÙfenwere C afc /ìr he child th e class t Then in TheY i; on.' tve re sPonsored' wt girls all to ttle li light P' For Y ears onIY s--and all thre e were a de iLls name is uhelr Bate 14 Ycar'; boy JudY nd a a 1"h'r son sPo nsor to lhose joY to asked s wa real ,rncluded t ifts 19ó5, th e class ine, handsome boy and a proje< s clas r p linic Harnmock î heisaf va cati ono Othe Pan A,mer icai jchool, Freeman <1ôn his of ek we the Oklahoma, homes during Ind ian OrPhanag e1n Bibl e SocietY, At': rican to the Co' tl andâfld Ame 1s individua ' t' 3 SUPP lies were -.Ld librarY. church and the was Paid teacher rY ho.l. i rsh iP funds prima i'rrI a PresUy Lui' th e sala tY ofPre e rra n HosPital" sbYt m1 ssions, where the up for fund has been set chine rna " given a sewing ' Mrs, i eth anniversa rY twent its ldren ,buta c1 ass observed ers of Young childreni Hono InJ afi)at¡ , !965 ' the I 1 y young moth L' o rigina grand chi "We were ndmothe rs of YounB the ED ITH PATTE E CI.A gra Watson rem inisces: changing to Young na me of ou t cLass to present, we afe gra duallY to change the 3L. SixtY-erg iìt m(:rìbers were voted we r, our teache was ma de on JanuarY 1led the Years gone bY, This announc ement ents who reca in the Library cluding manY past Presid the cl ass metMigh acilities, ty Acts" f its was enlafg ing stud yof "God's The church the ile ltIh in the Youth Building ' which wa s tenPorarilY known that ne whe n it was ferm âs everyo rised ace Cattet, surp aftex Gracers where they The President' Gr the waY. She wa s born right back was on as though theY were lt fe little Chri stieover' class whole Th e president w as agol of rs started, twe ntY Yea un timelY death the bY saddened and be missedo th e class wa s shocked who will always rs membe On March 14, the most f aithful new Lucille Winn, one of room tI5 in the on given was was held the EDITH PATTEE CIASS Program' sPecial a with In October'' Lg65,dedication service, A ca tional building" tha t she wou th at fitsí sundaY' announced r TaYlo up'--and the new roomt Í7azeL TheY were soon windows. the Soon aft,er occuPYing for make dra peries have her d ecorator Mrs. Patße most aPPre cia t ed" interesting" most that h the Ages" has been each lesson so The' study 6f "Throu$ e most imPo rtant lin es of derline th had the class un for future lessons' serve as a refe rence will Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 82 was most r ewa rding 33 " The Spring Luncheon in ,196ó was at NorthPark Inn. Despite the stormY ove:r L00 women" Mrs. Patbee reviewed weather, there was a record attendance of A1ike. the hilarious book, ALl the Crickets Look after the L;ncheon, Mrs. Pattee's doctor decided she needed a resÈ for awhile. The ;lass was iort'unate er absence--Bob Wi.1son, Myrna Li'ttl e' , Dr" Mohns, and Mabel Fl.inn. S'¡me of g this time. One of Ll.re most ou.tstand* told some ver'y interes'bång'Lhings who Thompson by Torger given ing lessons was s'The Lord's Supper." He also discussed his own painting, painting, ,oå"i tr," Pentecost." "The Miracle of Soon Wc:stminster Class Age had begun' In 1945 the Second World War had come to an end, The Atomictime "A trip to jet planes, rockets--for the first We were hearirg of computers, thesti;realmeaning.ByLg46manyveteransandtheirwiveswererêturn'experiences they inÁ fton .i to this church. These young people, because of the were probably in, lived had been through ánd the great changes in the world they generation" any more of a,,Group Apart" as they cutã ittto adulthood than alntost needs of was no class in oP eration here at that t:ime that suited the Betty, wife, his and So with the helP of the Reverend Mac Kennedy Class was formed" BY the time bhe second vea r had passed the Couples the Young to answer class had "jelled"" The otganization was set' Mac and BettY had left become had Black H. Dr" J. the call to their church in Shreveport, Louis iana" was Ín Mission Medical Da1las the class's teacher, friend and advisor' The West By class. by the financed oþeration--the first of many projects wo rked on and todaY. s'c remains i.': thls time the name had become The l¡Iestmins ter C.lass and Not the beginning the Westminster Class was restless--dissatisfied' The itl'kind. about something the complaining, irouctry kind, but the "Let's do approach was to know and like each other at the working and social" l-eveL. To .acconplish the objectives regular social func'tions have been held--some simple, some elaborate, a1L fun. Thãy have had projects in which the cl.ass members have lrorked witt¡ thåir hands and their money. They have not onLy encouraged individual partlcipation, but have insisted on it in class worship, programs, projects, gettlng out the paper, telephoning and a multitude of other tasks, large and They alwãys foun¿ t-tre reaáy hand, I often have heard people say, "Don't 1n1rr. join that Westminster Class unless you want to work, they work the life out of )tu.rt-¡a sLncere compliment. . From estminster Class is reaching maturity, twenty-one years its next In that length of time there are far too many names, dates, and events the space we have here. History of names and dates tends to be cold clln j.ca l. History that is warm and alive is in the results--what has 1958, Dr. Black was giving his regulat "5th Sunday" lesson' for his many b]-essings throughout his tife" At the eontook his seat, suffered a heart attack and died in his class antl 1n He had given of himself to his God until the very end" This.1 asL e¡ron wâ s not lbst on the members of his class. Dr" Black surel,y deserves edit for whatever of worth this class has produced. It has t'een One of his fond desires was that the c,las s ¡-rndertake the suPPot:'t; lY' In the year of L951 the class started contributing to the Novernber 30 ttTha nks " 3'+ Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 83 I¡Iho are in Japan' The support of John and Ginny Barksdale and their f'arnrlyr uó u"til uhis Ûime" lf one class has continued to send this support each year 1no"" of hhis church and others' both would Lake the time to check th";;;;tã", f rom this class are past and present, he w,iJ-l find a high perce nlage of people rnembers and commitiee church school .teachers, choir *"*u"i", deacons, e.lders, be found" Ll administrative workers.-,-wherever the áct¿on is, they wi There are even a coup.Le o'f ministe people are all giving of their time and fife of their church. Much of lhis desi measure of success for any class should and 'to the comrnunity at large,?"'r By bhi a great class and has the potentíal of a promise of the Past' Eltiott's CouPles Class ': of our senior The Elliott,s couples class was founded in l-953 in honor as one mainly for young minister, Dr" William M. E11iott, Jr" The class began same "young" couples have or newly married couples. Over tfie i".t" many of these their Class an¿ now it consists nrostLy of couples in sunday stayed with the Elli;tt's meets class thirties, However? anyone of any age is most welcome. The r15" 9 at mornings at 9:30 with coffee fell-owship Startingthreeyearsagotheclasshastriedtoscheduleafellowshiponce the class members" since many a month on Sunday evenings in the home of one ofthese provide a means class members are teaching on Sunday mornings,class' fellowships main purpose their However' of introducing new member-s an¿ friends to the Lord, Jesus Christ' These fellowremains a way to share in fellowship with our shares something of slrips usually consist of a testimony and a lay speaker who our Lord with the class. Besidesthef'ellowshipsbhereareaSummerbackya.rdicecreampatty,a guest and speaker' and a birthday partFwith Dr. El-liott as honored informally speaks Elliott Dr" This is really one of the year's nijnf.ights becauseq'uestions in return" to the class and the class has a chãnce to ask him of a missionary couple other activities of the class include partial support for hospÍtalized baskets Easïer makÌng of and cLass projec'ts consisti.,g in the past and supplyworkers' f'arm transient children, providing Spanish'-Xnglish SiUtes for at ltasca" ing athletic equiprnent for the Children's Home christmas party, Eleven O'Clock Bible C[ass In the spring oÊ L954 our church, having inc¡eased in membership and attendance'Wasexperiencinggrowingpains"Inordertomakebet.teruseofour classes in all departments of facilities, tt¡e ¿etision was made tã ínstitube dual 9:30 worship service could go the church School so that those who attended thechange was effected with good to Sunday School at l-1:00 and vice versa. This results. became necessary to There being no class for adults meeting at lL:00 it had its inception" A form one and that is when the Eleven o'ctrock AduLt class which the class was fortned' few dedicated individuals became the nucleus aroundthe leadership of various inMeeting in what was then the church Parlor, under for existence dividuals from the Church School administration, the cla'ss struggled 35 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 84 e Eleven O'Clock Adutb Class was ven. Dr. Hubert Hopper was the first 1958 the name of the class was changed Founded on the basis of necessity, the class has developed into one decome the practice of the class to and it has furnished many teachers ents. Mission minded in its benevolent qua11y between foreign and home mission causes. present membership roll numbers 30, 10 of whom are charter members. The Boand Couples Class This class of young couples originated in the spring of 1958' At that time list of charter members who it was named THE JUSTERS. Ten couples composed the planned to had decided to use the discussion type of lesson presentation and The charter members iur'ist a majority of leadership within the class itself' Mr" and Mrs. *"r", Mr. and Mrs. Jas. Anderson, Mr. and Mrs. Douglas GibboneY, (stip¡ Kriedler, Lloyd Robert Hamblin, Mr. and Mrs. Robert Knight, Mf. and Mrs. Rumley' Mrs" John Mr. and Mrs. William Lacy, Mr. and Mrs. James Mclean, Mr" and Mr. and Mrs. David Trent and Mr. and Mrs" James lr¡eatherford. Not only was response great in Church School, but outside as wel-l" TH-E xvery JUSTERS were constantly looking for, and finding, projects to help others. weeks home from Christmas and Thanksgiving the class members would collect food in advance of the holidays to make baskets for needy farnilies. One trip was made to Oklahoma by class couples to visit the Goodland Indian Orphanage in Hugo, to which they had been sending yearly offerings. There were other times when the class gave of themselves as well as their rnoney to help those who were in need of it. had close fellowship with each other, and this was witnessed by social gatherings two or more times a month. One special event is sti1l being carried over through the years. This is the progressive dinner pafty held during the Christmas season. THE JUSTERS As the members grew in maturity, it was decided that the class should no longer be called THE JUSTERS, as most were no longer newlyweds' It was at this tirne also that Dr. Arthur V. Boand retired from his ministty at our church" In his honor we changed our name from THE JUSTERS to TTIE BOAND COUPLES CLASS" Since it is a young couples class, the membership changes often. Many have out of state to new job opportunities, and many have had to change churches due to their buying homes too fat away from our church. As a result, the class has seen many new faces, and many new friends have been made throrrgh the years" moved As the membership grew, so did their famiLies, It has been a warm experience to be able to share with each couple the joy that a new baby brings to their home. had many interesting teachers, Mrs" David Trent reports, us to grow in our lmowledge of the Holy Scriptures, and have helped us to Lee how we can apply this knowledge to bring others to Christ. " THE BOAND CL^ASS has "who have helped 36 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 85 The Timothv FellowshiP Chur is a group in the Hi ghland Park PresbYterian non-menbers and members both for single Young adults" Its membershiP includes ers of the grouP be members qf the Church" It is required that the elected offic as committee chairmen. Ma ny the church; however non-members can, and dor serve ciated with it initiallY young adul ts who have joined the Church became asso The grouP Probabl-Y through particiPa tion in the activities of the Fellowg ship. the Church" One in roup has the largest turnover in membe rship of anY aduLt aduate" from the grouP bY reason for this turnover is the f act thab members '?gr lt groups originallY met in marriage. ManY couPles now assoc iated with other adu Timothy and graduated together. The TimothY FellowshiP The grouP ordinarilY meets each Su followed by a program consisting of a br and usually a guest speaker. The progra and secular subject matter. After the p either at the Church or in a private ho chance to visit and get better acquainted' formed bY some of the sin The fellowship had its origin in a bas eba11 team into a SundaY School Class, develop ed young men in the Church in 1939. This group in the room where Dr" KennedY's studY taught by E. N. Johnson, which initiallY rnet l-ma1e, it was not long before it is now located. The class was originallY aL was it sbut teacher, the class was known became ttco-ed.tt During the tirne Mr. Johnson as the E. N. Johnson Class" used to attend church Afterwards it was called the T&C Class' The members other SundaYs for coffee services as a group on alternate Sundays and me et on the and sociaLizíng" young assistant Timothy' a The class later adopted the name of St. Paul's of young adults name deemed particularly appropriate for an organizat'ion ' as Carl AnderClass membership increased during the tenure of such teachers and Fielden Gaither' son, D. W" McCord, Ewel1 D. Walker, Chãster l¡1. Chambe¡lain attendance in the norning Sunday evening meetings were begun, but for a time two factors primarily conexceeded that in the evening" Howevel, åventually in proportion to tributed to attendance in the evenirrg ir,"r".sing substantially that in the morning. ' One factor was that a sizeable num members of the Church, and many of whom rnornings, began to attend the evening me of the group. The other was the fact th teach in the Church School on Sunday mor of Louise McComb, Director of Christian while others began singing in the choir, The class became the adult class with th in the over-a11 Church program on Sunday mornings' meetings' Members In 1958 the Timothy class discontinued Sunday morning norning adult Sunclay other became involved with evening study groups and with formed' but been have adults classes. Other Sunday morning cfås-""" ior singlewith the Timothy group meetíû9 these classes are not organizationally connected on Sunday evenirigs. JI Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 86 activit ies ' probably its principal benevolent prounshine Home, the Dallas County home for st once each month the group takes bhe lude such activities as parties, picnics' oup has taken the children to such places Children's Museum in Fort Worth, and f the outings, however, is not so much ssociation with the children. Sorne of n during the school year. At Christmas . Sponsorship involves providing money ldren shopping. In 1960 Paul Peurifóy' ard, presented a Distinguished Service the group had contributed to the Home' been invol-ved' off and on Another benevolent project in which the group has en at the Presbyterian Children's Home at sharing financial responsibility for e year' visiting the children at the Home aining the children in Da11as for one up has sponsored include Charles Yaughn ilver and "Marie Schaefer" ,Thegroupalsoengagesinotherbenevolentprojectsasneedsbecomeknown andfundspermit.ApartofeachSundaynight'sofferingisplacedinascholarschool' For a number ship fund to help a young person attend college or trade Center at Chonju' Medical Presbyterian of years the gto,rp ¡âs cór,ttibuted to the hundred two over for gifts cho11a Pukdo, Korea, to help provide christnas to missionaries church's the to children. The group has given sound equipment the Congo, the William Pruitts. spring and The Fellowship usually has two retreats each year, one in the groups adult young single joins other with one in the fa1l. The group generall-y in the State for one of these retreats. a married In addition to a Staff Sponsor the group usually has as Sponsors and Mrs' Mr' included have sponsofs couple who are members of the Church. These Mr' are sponsors present The Little, TomMeredith, McKee Yant, and Charles R. Mohns' A" Edward Dr" is Sponsor Staff and Mrs. Richard R. Catherall. The current Past presidents of the group include the following: Arthur Rodgers, Darwin Renner, Lionel Gilley, Ruth McCorã, Mildred Watkins, Ed Fenner, Reece Wyant, Sidney Davis, Dick lrlyman, Earl Weeå, Dudley Penick, Don Brown, Ted Jones, Howard Dunhaå, nalpú'triood, ¡¿ tvterritt, Talmadge Main, Charles Wood, Gordon Thra11' Laurel'Mille;, A1len Cain, Ted Mi11er, Stuart Cowan, John Evans, Charles Goerke' Bob Carne11, ifr¡.f Huey, Russ Rowley, Hobert Price, Ted Miller,. Frank Schumacher, David ob;;iå, Spencer Relyea, DuanL'Mclean, Jim Cumbie, GilbertAdam, Lee l'{clane' Jerry 8e11, Larry Haby, Hal Kobey and Jo Cutler. In additi on to these organízed classes, there are discussion groups meeting on Sunday at bo th the 9:30 and 11:oo sessions. one is studying the covenant Lífe Curriculum text book- Into Covenant Life; the other, the current book' ry Chr ist ian Life. In addition there are meetings through the week' both in the mo rn and eve ning, for CLC studY and discussion' Jò Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 87 Two very important Sunday meetings are the dr¡a1 .sessions of the tea chertraining class in which those who a re considering Chur ch School teach ing ght'-months L967-68 are being schooled' The ei program for these dedic atedin peo futurq is an invaluable procedure for both the teachers and those who will be J-earning from them" There is also a new member orientation cl-ass providing an eight-week cou on a continuing basis for teenagers and adults interested ,in becoming a mernbe¡ joined the church already but wish to learn more the church or who have about i For the large numbe'is of children and yo Itrng peo p 1e be,tween the a ges of and 18, who are ready to come into ful1 communion with our church, the re ale special communicants classes each spring and fall which provide a thorough-go six weeks of instructíon on the doctrine s and gorte rnment of the presb yterian Church, with special emphasis on what it means to be a Christian and the respo bi,lities and privileges of church-membership" This co mmuni.cant-class period culminates in a special Candlelight Cornmunion Service at the naster and Christ_ mas seasons, At these services the communicants are welcorned into fuLl by the minísters and the Session. You may wonder who is the organization¿1 head of this complex and ever_ we call the Church School" of course i_t is the Church School Superintendent. From one of the past- superintendent" growing institution "or"-of-ar,""'iroUfems of that office are glimpsed" It is difficult to imagin" tt,"-rãiy".J"ior,"Lbilities that rest upon this man" He is elected by the Seãsion to administer the Church School for them, under the supervision anddirection of the Session,s Christian Education Committee" The challenge is tremendous, the-problerns manifold, the frustrations neverending and labor unlimited; yet even with the manv. many hours that are required each week, attending meetings, counseling wit¡ ståir, ;;";;;r';;: program, r€_ cruiting workers and supervising the entire Church School ;r;,ir;;-it is one of the most rewarding and enriching experiences for personal Christian growth and witness that a layman can undertake" To give some idea of the magnitude of our church Schoor program, it requires 350 to 400 people to staff the total operation" With a fruiã ã"rí"r"tLp, such as we have, it becomes necessary to enlist new workers every week fbr different reasonso Many talents are required in a superintendent__h" must ù"many gooa a listener, a personal- counselor, electrician, carpenter, plumberr locksmith, heating and air-conditioning expert, policeman, janitorand truly u g..ã "å.i."t of the Lord" 39 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 88 CHA.PTER V WCIVlEN-OF-THE-CHURCH rrrrÈi ¡u¡¡s Moneywasgiventoth<buildingfundandanequipmentfundwassetup.one reding yeal, was when the fi that of the highlights-of all< :.i:::"::ä'.T: :Ï-i:Îi"l;' food sales at th Executive Board met and 'åiÏ.äilË"îrl'lå"ii1oi?T;i", vear the ring tnã rirst times' when turdãys' Many LL^j^. rolls, cakes and cookies at back their own few customers came, the women bought the end of the daY. women held oneoftheearlymoneyraisingprojects.'l"u,,PureFoodShow'lgivenina Shop is now located' Mrs' vacant building on Knox Street-.-w;";"-Flãwer-A-Day_Ho'"*made MarkLemmonwasChairman.Spacewasrente¿tovariousfoodmanufacturersand foods were also sold joan wholesalers, where they had attract¡.ve exhibit". Lawther' daughter of the features" aud a baby-show was one of the special exhibitors Between the rental of space to dollars" Joe Lawthers was judged ttre pretiiã"t" thousand Auxiriary cleared over a and the sale of home-made things;-;;" wornen's Itwasin|g2TthattheBuildingCommitteepresented.l:,1:*'liary':lith Lg27-28' money was raised by the the task of equipping the ctrurch] iã"i" did to add to itr" futt¿' Dr" Al-exander' self-denial and by extra wort t¡rå women inhiskindlyway'persuaded-thewornentogiveupallplansforraisingmoney' inst:ãd" This plan has been but to give what'it"y could fror lÀ"¡.r own funds in force ever since" 40 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 89 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 90 patients of our They make cancer dressings of all required sizes ;for the charity mentioned but the bhree projeci;s on many to carry ,o""ty. The l^I.O"C. continues Christian in of'growth indeed, marks are work and ã¡ou"-have been new to the ,{c t íon. In 1961 the General Assembly of the Presbyterian Church, U"S" met in the in which they responded to every HppC, and the women were superb in the manner and their wives. commissioners the i"quå"t made of them in entertaining The Auditors Report of August 31, 1966 showed that the V{omen-of-the-Church their World Missions and contributed through their regulãr budget, and through year L965-66' The women confor the of $26,892.80 firtnaay Offerings, a total plus special benevochurch, of the benevolences lrlUut"'to aL1 oi ti," regular (six are fu11 scholarships) of which scholarships plus seven lences of their own, colleges" and to our denominational schools At the beginning of the 1966-67 year there are 2,966 women Highland Park church--this includes the out-of-town members. members of the Bible Study continues to be the heart of the monthly Circle Meetings--theon Bible teachers meet regularly with Dr. E. A" Mohns for study and instructions planned teaching the monthly lessons" The General Meeting Programs are careful-ly suggestíons and closely coordinated with the program of ouf own church and with on programs offered splendid also are there l,{ork; from the Board of Women's serviceo opportunities for community Bible Stud¿ Leaders As far back as one can remember in the general history of the Women-of-theChurch, the Bible teachers have been a primary consideration in the formation of the Circles. In fact, the teaching of the Bible was to most of the women the important part of every Circle meeting" However, otganí'zation of the Bible teãchers as such, with a special day upon which to meet, with a special teacher, was to be a part of the growth of the church" In the early days of the Highland Park Presbyterian Church, th9 organizatlon of the Circles as such alwayi included a Bible teacher. llost of the time, thls work was done by some dedicated Christian woman within each Circle. Whenever a teacher was unable to be at the Circle meeting, the situation was dealt with as the need arose. One of the early Bible teachers expressed herself in this rl¡nner: "The Circle Chairman told me they needed a Bible teacher, and she gave tlte a book and said for me to be it"" And she was it,i As the Church began to grow, some orga nLzation had to take place" A 1itt1e 0Ore thought went into the selection of tlps e people who were to bring the gospel ¡lêss age to the women in the CircLes. A Chairman of Spiritual Growth was chosen, in a spirit of prayer, with the help of the Holy Spirit, various women in church were a pproa ched to undertake this tremendous work" It was a iime of fo¡ the wonen of the church were exposed to the finest teaching efforts of ninist e r s and teachers as Dr. Sam Joekel, Dr. Manford Gutzke, Dt. Lucy te, Dr. t¡t illiam A. Benfield, Dr. David Stitt, Dr. John Calvin Reid, and othe rs. y there is a special cl-ass of instruction for some sixty Bible teachers rth Monday of each month. This class is taught by Dr" Edward A. Mohns, achi ng minister on the staff. But, al-though there is a more systematized 42 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 91 method of instructio have been Bible tea not see each other separate wayst but v the Master"' ;;i";;;; ""'"å¿ The Ttg-"duY Morning Bible inbo being Bi b1e Class The TuesdaY Morning of women unab le group ínstruction bY a came Bíble Class to becaus attend the e of the desire for Sunda y morning classes" times of trans during a few skiPs with ears, nd women readY the Y It has continued through And be cause of th e ded.icated men a tion, because of that desire. to suPPlY the answers , as teachers' Ande rson--honored The first was Mrs' Charles deceased' and revered--now war Years' readju stment instruction; after women seeking the kePt ars of the new morality' War Ye and now th e age es, tim rnodern g years, trYin took the Podium' incl teachers fine of Balcom" Mrs" Anderson a number Following ing Dr" Dubose, Mrs' Wm. M" E1 1iott, and Mrs' Homer Church and he was cal1ed to the minister addi tional Twelve Y ears ago an class' this of assumed instruc tion Bible and the PeoPle of the tual Mohns, A. rd Edwa a life of sPiri of Dr" towards lems Under the gu idance to assist us w ith our Prob Himse lf were summoned ir rational world' common sense in an Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 92 43 "tl CHAPTER VI MOSTLY FOR MEN Elders and Deacons All organizations of any presbyter which consists of the activ Session, the pastor and associate pastors" Fro --the comes the authority fo¡ the position of grder, Chapter 11, article 3, says this: blameless in life and sound in the faith, men of wisdom and discretion. By the holiness of their works and conversation they should be examples of christian faith" " Also from First Timothy, Chapter 3 , verses 8-L3, is authorit y for the position of deacon" The Book of Church Orde r, Chapter L2, articLe 2 , reads as I'To follows: the office of deacon which is spirituaL in nature should be , chosen men of spiritual character h onest repute, exempl.ary 1ives, brotherly love, warm sympathies, and sound jud gement" tt The Session is the lowest of the four courts of the presbyterian church, u' s' The loca1 church sends elders as representatives to presbytery and Synod, Each Presbytery sends commissioners to the General Assembly--the highest court in the Church. - The Session and Diaconate of the H ighland Park presbyterian Church meet t1y on the fourth Monda y of each mon th except for July Au gust when : regular meetin gs are dispensed with and business is handledand by ca l1ed meetings ì¡g needed. The joint I tha t needs a ttention meetings are for d inner, felLowship and for any business of the two groups. Any matters reguiri ng action by both : $rOUpS are S ubmitted to each boa rd at its separate meeting fol-lowing the joint The relationshio the Session and the Diaconate of our church is llent' Each has it" between o"n duties io p".rotm and each does it we11" All major rttees that reoort and make recommendations to t,he congregabion.are, r Joint commitìees of the session as a and Diaconate" On May 9, 1926 when the organization of the Highland park presbyterian complet ed the following officers were e lected: Ruling Elders--Har ry ' hn W. Geo rge, Lewis T" Carpenter R. M" Vaughn an¿ Wl-ttffiGnton; nW. Ca rpenter, J. R" Coulson ï,lurt e p Jones, J" S. pulliam, Henr yR. gh Hort enstine, Mark Lemmon, Cha rLes S" Teeple, Sr", and Sam R. Weems. of th e most i mportant decisions of the Se ssion and one of the fírst of the Session and congre gation was the seL ection of bhe church site ot!, Uni ve rsi ty Bouleva rd. A copy of the mi nutes of the Session of r l9z6 and a copy of the minutes of the co ngregation meeting of August follow. 44 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 93 Minutes of Session August 25th, I92'o held on Park PresbYt erian Church, and H" F and Highl the of At a meeting of the Session consisting of W' t4. Whitenton q uorum was Present, which at elec ted moderator and the date, this Ca rpenter was T" Lewis enter, Boyd and Lewis T. CarP were had: fol-1o wing Proceedings adopted' to-wit: was offered and unanimously ion resolut following The t Church the Highland ?a rk PresbYterian of J' Session T' of the bY Be it resolved ion that a committe e consisting d we recommend to th e congregat be aPP ointed and a utho rized and emPowere bel Carpenter W" Coulson and John site on UniversitY Boul evard, ProPertY close a trade for the church theY fi rst find the mea ns for financing su ing to Dr. Gílbert, P rovided of funds necessarY stto incomPlete securing the for this a tra de and find Plan intention of th is resolution to ve the in this matter" p urchase, it being lete, PlenarY P ower to act committ ee ful1 and comp su to carrY into effect imPracticable is it that other find for neg otiate If this committee shall then they be instructed to to be submitted bY dicated, in land the for trade to the Session; make a full rePort suitable ProPertY and gat in turn to the congre ion " adjourned' to be transacted' the Session There being no furthe r business /s/ Lew:.s T" CarPenter Moderator /s/ H. F" BoYd Clerk of Session Meeting Mi.nutes of Cong regational L926 SundaY, Augus t 29rt,, rpose of ratLfy"ing the action of the cornmi sl the Pu This meeting was called forand r n closing trade on church CarPenter Itr. John moderatort compo sed of T. J" Coulson Jno. W" Ge orge was electeda nd read Mr. Boulevard' versitY Uni prope rty on of the meeting Coulso n stated object the ProPertY in quest for t H" F" BoY d secretarY. Mr. contrac sales a tained con fu11 y describ of the commL ttee which or on UniversitY Bou levard, more 1ess, more acres, being 9.85 of $52,500"00' sa id contractlataPrice and John W' LemlY' T. J" Coulson Judge bY and Sam seconded On mo tion of Mr" Weems' Lewi s T. CarPenter moved be au Then church" the for the Tru stees ed we re elected trustees rePort be aPProved and Lhat I ttee's commr the that n d seconde and uPo the terms stat olthe Price f proPertY addit the n nominated to c1o se the deal forthit he una nimouslY" Weems carried bei ng s vote a pu bo t being and H' F' Boyd, it Davis R. HenrY rec eiving a s econd t a trustees, naming W. M. Whitenton, nominations se The three of best to ha ve five inst eadthree Pa rt" ies rn entíoned were unana mouslY e lecÙed Coulsont being Pu t to a vote, t he being as follows: J. T" a s now constituted board The Trustees. HenrY R" Da vis, H' F. BoYd" Carpenter, ü[" M. lfhiten ton, the meeting adjourned" There being no further business /s/ H. F" BoYd Clerk of Session Defendant's 45 Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 94 Men of the Chur ch Shortly after the Highland Park PresbyLerian Ctrurch was organized in Lg26, a need was fel-t for a men's fellowship group, an opportuni,by for men to enjoy fellowship together each month in a constructive organ ízati-on. So in December of 7928, the first Men of the church organization was founded and Harry penniman, Jr. was elected the first president. After a few years, however, the organíza'bion . ceased to function. But, as years passed and the church continued to grow, more interest was expressed and action was demanded for reorganization of the t4en of the Church. Through a truly intelligent, well-pLanned program for men, it was unanimousJ-y felt that the men would find themselves involved in the church's overall program" And as years have passed, this opinion has been confirmed" When the Men of the Church group is strong, more men take part in church affairs as a whole. The basic philosophy behind the Men of the Church is most important and should be defined" rt is a three-fold philosophy and each part is essential for a stlccessful program. These necessary elements are fellowship, inspiration and instilction or education" The Men of the Chu.rch is not simply fellowship, but to be worthy of its existence and use of dedåcated manpower, it must provide enco!'¡ragement for its men and enList their srrpport of the church's program. This is done by having inspiring meetings which keep the men informed and challenged to service. The Men of the Church organization can and does provide these important items more forceful-ly than any gror_rp. 'ther Although the first organization had faltered and all but disbanded the , second Men of the Church functioned throu gh the depression but agaín, as less and less emphasis and support was given, the group barely existed, sometimes going months without meeting. In 1939, the need îor a strong men's group was nd after careful planni ng by a special committee with Mr. Dyer as irman, the Men of the Chu rch was reotganized with L" R" KleinGibbs serving as sident. The l. following three-fold objective was adopted at this time: Living and witnessing daily, as followers of Christ. 2. Strengthenin bø and supporting the program and services of the Highland P¡rk p resbyterian Chu rch Planning, developing and promoting a wider ferlowship, a broader a more active participation in the work and extension of presbyChu rches and Presbyterian services and activities in Dal1as county. e, and its reo rganization the Men of the Church has sponsored fograms and many men have had cause to become active in church the , because of the varied informa.tive a nd chaLlenging meetings y earso acconplishments sponsored have been: ^Sone lfo a number of successthe overall program rkin Phv síca1ly and through visita Lion wi th t ensiqnc ilch urches: numerous ri e ratin I wi¡¡ Hope presb yterian Churcir and its nc e in the program; lsta of the new men by t'Ex- providing 46 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 95 " -? \a| t.¿ ''' (lr a m:lssionary for to purchase an automobile Providing funds the McAlPin o f JaPan). for teachers in recruit to men in te aching Places e Quotatt of 50 over onl y two men wilth were e suc cess and AccePting a "Challeng ther s time me t (at thí was e I Since schoo ght. challeng church a lmos t overnr division ); this aching Pro8 rarn te in the child ren's the rol es in the tea chinB into t rtant brough e impo wer five men n have P laYed rnore and more this time me heretofo re women mos tlY servedo then program where work wit h the to ves i at resent reP t active in James and ecial comn itteetion Appo intíng sP Program visita ShePherdil : mos These fnen were 20 men inued" ApProximatelY the Plan was díscont this program unt ilting the M .O,C. served on this Program' r S Program directlY ÍePresen o f the AssemblY resídent aP as a SYnod's P rovided a 1so served have had Church who the R. K1ein, Our Men of as PresbYte fy's Church; Mr" L" Wa tson served B" tín for Men of the Aus tion Mr" President ' In addi as SYnod ts Vice-?res ident " new "Flock Presídent and later Conventions' Assembly Ments four been seateó. e There hav High land Park (Dr. ia, Georg tlanta, present, in 1949 in A m en were The f irst was held ates' A tot a1 of 4,000 ention' ) this conv twelve me n as deleg sPeakers at the of one Elliott wa s this convention was 1954; in sea ted rleans e rian church ld in New O 50 of over The s econd was he men and Hi ghlan d Park Pre sbYt WYnne Lee die Tod 9,300 by of Mr" att ended to the gqnero sitY Pr ivate Planes' WYnne's Mr" ó3 men. Thanks in there these m en were flown 9' 500 att Mia mí. Around in bY 195'7 in was held was represe nted rk ?a convention rd The thi once again Highland by Mr. $lYnne " there this gre at convention; over 50 were flown 61 men and again the chairman as in June 19ó3; rted bY the me Dall in ld he was and fullY suppo rman r The fourth convention t o the cha i ention wa s Provided conv for this g reat n Church" In ?ark ?r esbYte ria add:lt ion six sub- committee of Highland Watson' Highla nd Park P rovided ttee whic h artange d Mr. Austin B. the he ad of th e Financ e Conmi ivities f or the vr sitorc men' includ ing ente rtaínmen t and oth er act convention and in funds to Pro vide way s, the mos t outst anding nen had a verY This was, in manythe great Perc ent age of the V irginia, Geo Carolina, of the fact that (from Florida ' North atta ined ' ve1 tra to was tance o f 8,300 men etc') an att endance the Foreign in assisting at ies, diligent Mission were arra The Men o f the Church nding confe re nce of' Nlissionar also who outsta Park men ghland Hi Conference ' An bY was sponsor ed visitors" Council Membe fs and comfort of the ions except each month' of t{ondaY LLY a on the first <li nnef, Usua bY men have met Park ceded pre a re te va Highland Pro g rams a Wel 1-Pl anned Programs ma inp togfam. 11 t months" the religio summer ed before litics, fpo o is Present cha Lletg, entertainment laym en in the fields have been h men churc nding the Years, and have viding outsta areas" Through sibilitY in the chu rch, other and resPon 1aw, science to accePt th eirmen" come forward have better ed andMotion Defendant's Affidavits in Supportinform of First Amended for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 96 been better a 47 ccommodat Unfortunately, we cannot list a1J- presidents of rhettMen of the Churchr" however, here are those we can find in the records avai,lable; L. R" Klein Ted E. Jones Harry E" Blocker Neil Raymond Myers Dr. fr rank Kidd Edwin N" Saylor Frank Phillips E. D" Sheridan Johnson Tom Finney Brookin Wadley W. B. Kendrick Cliff .Jones Wm" Craig Mi!.lís J" R. Fulgham T" W. Norsnt,rthf W" D. Kiebler Austin B. Watson Tim Welch Alfred H, Benjamin John Wagner are treated to a visit to Mr. Toddie Lee l4lynne's Mr. Wynne, Sr' and Toddie Ranch for the first meeting of the Fall" Hosts are or six i."-Wy"nu, Jf, An average of 250 men are present to ride the five the ranch at buses Mr" Wynne provides and enjoy the barbecue and hospitaLity tomeeting for this iãar fauf.arr. Our rnen are always grateful to Mr. Wynne Each September the men gether" Among the interesting prograi;,s there are: Father and Son lt'ieeting, Swcetheart Meeting (husband and wife), Dr" Elliott's nrght (an annual highlight), and Christian Education night honoring Church School leaders" Ushe ring at HPPC In looking back through the years as disclosed in the records of the church, it is in teresting to note that the first reference to ushering was 1n July,1928 , when the chairman of the Board of Deacons reported that for the tfme bei ng, thre e selected Deacons were to arrange to act as ushers each Sun'During the falL of Lg4L, ushering took on a new imporbance ín the life the 'of church when the first service was held in the new sancbuary on Septem, 1941" Guy F. Cahoon was at that time Chairman of the Ushering tee and reported in some detail the plans for serving the congre ga tion new building. Wy 1ie Sims was of considerable assistance to Guy Cahoon ¡t that time, and the st aff of ushers was expanded to 16 Deacons to serve at llt services on a particular Sunday. The leaders, known as captainsr were at time Julian Foster and Chester Cole, fter a number of years, ushering became more formal, particularly under dership of EarL Jackson beginning in 1948, and later with Carl Scholle over the Chairmanship of the Ushering Committee. During this period years later, it became evident that ushering like all other work in must be studied and developed" ater years such men as Harold Faulkner, Stanley Lindgren and Herbert e contributed greatly to formal izing, expanding and developing the aspects of usher ing at the Highland ?ark Church. Such Leadership has organized ushering a staff of more than 300 men to serve at aLL the church and has included tours of the church building, a c'hurch the development of youth in this phase of t'he church's life" ' and during bhe year are reserved for young people who have had trsin in youth work including Youth Sundays. Experience at th ere are many usheri.ng instances where the youth has responded in thís well as adults. 48 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 97 DeaJ-ing with so manY men anri the entire congreËation, it is only natu that some humorous experlen ces would be encountered -srlch as the individuql I'Is Dr" continually asked each Sr¡nday morning before entering the church, -El"1iott here today?" This particular usher, growing ti.red of this question answered, t'I do not know, brrt God is he re "'t It might be difficult for some people to understand that certain individuals are not exactly suited by temperament to become an usher, as on one occasion, a new usher became so nervous over his first assignment that he was covered in perspiration and shaking. Of course, he was relieved of his dut ies and he found other work in the church that was more pleasant for him" In recent y ears there have been many ocCasions when other churches have asked for tal-ks to be made bY a rep resentative of our church on "How Ushering was Organized and How it Operates at Híghland ?ark"" We have also had many inquires from other churches for a copy of a manuscript on an unpublished book church ushering. Copies of this manuscri pt have been furnished to several chu ilhe organizat, ion of the ushers for some time has been divided into several sections such as prospective ushers, reserve ushers, and regular Sunday morning ushers" The organízation is under t he leadership of a committee of the Diaconat It is the obj ective of the leadership that each usher will come to realize his work sa that church ushering has its own reward. Every usher who performs doing an impo of satisfaction the have irit wiLl factorily and in the right sP body of good a that always remember to and service rendered to Christ Himself, splenushers, a1ert, constantly seeking to improve their service, dedicated and example. by their congregation re whole a ínspi can didly 1oyal to their church, 49 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 98 ii: CHAPTER VII HPPC HOSTS THE GENERAL ASSEMBLY the Place is High land Park PresbYterian Church; the The y ear is 1961; of the Presbyterian Chu rch he convocation of the Genera 1 AssemblYa nniversary of its founding States. HPPC is observing the 35th year of its organízation a1 AssemblY is celebrating the centennial ry--surelY an auspicious co incidence. formal ga thering of Commissioners--who, inFor som e three Years before the had been thoug htfully and careful-lY made" a11Y, numb ered 553--preparations committee consisting of coR. Klein was g eneral chairman of an executiveC a11 W. Huser, Lucian TouchLee WYnne, Sr. I James C. Hurlbut cha i rrn an Íoddie ex officio" The E. Wilkin, J ro and Dr. William M. -clliott, Jr", stone, George of the ir task can best be indicated bY de scribing some of the scope and magnitude s sub-committees. specif ic activities of variou Chairman, sent to the office of The Space Allotment Committee, Mr. Klein, the btrildíng, indicating the number of perthe General Assembly a floor ptan oiRooms in the church for 15 Standing committees sons each room would accommoda,te. assigned, five small-er rooms for 15 men each were --seating at least 50 men--were snack bar and first post allotted" An information bureau, u l"rpor.ryuna- for office, book store exhibits were allaid room, a press room, space fot ãispfäy" floor plan of the building with arranged and appropriaiely equipped. A small provided to be placed in the the location of the various assigned rooÛs was Commissioners' Packets. Building and Grounds Committee first aid equipment as suggested by Red First Aid Station daily from 8:00 a.m" u A second sub-committee, called Post-Offi receiving and dispensing mail but gave o place of each Commissioner and the loca Another Building and Grounds sub-committ ing cleanliness inside and outside the rooms and eating areas. The installati four extra phones and special attention to the public address system also under the Building and Grounds Committee. The came The Finance Committee, Carl l¡I. Hu ing of items needed by other committees mittees and conferred with the Office o specific items. This committee also au to Commissioners, had the check"-"titt"tt, given for signatule to the Assistant aistribution" for post-office the Stated Clerk, who, in turn, ser,t ifrã* t" the Jr" The Registration Committee, under the chairmanship of George E" Wilkin' unan for responsible was in a¿oilior-io u""igning hotel táor" to Commissioners, believable number of details for the comfort and information of both Commissíoners and and visitors, involving the rãcruitment of personnel for booths in each hotel for a group of hosts and hostesses whenever needed' 50 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 99 took charge of Chairman, of Touchstone, Conrnittee, Lucian ch and hot els t the P rovision rs ione The TransPortati'on rtation betwe en chur ' rrse of Commis s the for transPo ening s for daY and ev as needed " a rrangement the parking ring du rtment for extra tesY cars w L th drívers the ?olice DePa with ts ttee worked months and arrangemen ?ub licitY Commi the Jr' t Chairman, General Councí l, at, tended to inWadleY, N" eoffee urn !\Ii th Brookin ty of the Publici of prov i- s ion of a and SecretarY eded ne ahead with the in the Press Room as of Phones ion llat a s',r at all hours' for music there with an attendant was respon sible knew r¡hen ?astor' host he as Elliottr Jrot 1 AssemblY Prog rafn Committee t selected and Dr" William M" er of the GeneraWi lliam H" Tag9t Musie Director,and other sPecial since, be ing a memb ipS ervices rable. He and Ass emblY Worsh music would be desi General all music at arranged fo r the occa sions. an ¡'mas Chairmant had t refreshme nts since F. Mealst wíth Robert dinners and ligh with the The Commit tee for il of lunchest Arrangemen ts ls mea gcod the Provision to keeP " portance beYond most haPPilY to conp licated bY the neces sitY react to tend ttComnissioners her wi th' were furt the Of fice of th e General AssemblY. start to ex y b comPl near the set caterer, the 1i mits ounter arra ngement within ls nea forac bars and of ndy too' cost ca t he cookies' respon sible, was inks, dr e The M eals Committe e direct sale of coffee , soft th lounge area Anundsen for Comrn ittee --he SundaY Dinner" ration Genera t AssenblY of the "OPe at ive to the was Chairma n sent Wood re C' ReP Arthur r and Board y, APril 30,1961" each Comm issione membe r on Sunda saw to it that H??C a of home ushers was a guest in the S' Rourke' Chairrnan--Provided on Ushering--Clifford Th e Committee the AssemblY' of for all rneetings the giga nticoftask Pa rt in the enificant s:a had also was Chairna n "F'rank ch Ayres L. RecePt ion for The Wome n-of-the-Chur A ssemblY. Mrs. the ing artang General of membef of e nt e rt a ining theittee wit h the sPec ific dut ies (at the home of a HP?C Tea Comm tha Ladies re e th F-nte rtainment WOÍl€D--fltO (in the church Pa rlor), Ina ddition, the rsonnel- for we lcome needed' Mode rators as of flowers ons and di nnersr p rovided Pe Commiss and the Provision t ypists f,or at secured a 11 the lunche the church, the of them--served booths at hot el and the snack bar for s ion rat hostesse ist as teg and ganiz ation ist rat ion t served woment s or report s and for reg s for TRAV' ilith the help of ent ertaining aPP roximate I and as recePt ionist lrlomen wer e fespon sible for Ass emblY. the r husbands t o General Da 11a s churches, issione Conm d their tables wives who accompanr-e ühe 1 uncheon fefor rs flowe the was Club took care of land DigB ers Garden CLub High The Chancel Garden the ittee Pr peI, and F lora 1- Comm WYnne Cha and PulPit rlor The the Pa SMU' ín A number of other dinne rta bles at the Office' for tor's ible spons and the Modera bY indi viduals " flowe rsi n the sanctuarY were furnish ed Reg afrangements r flowe at, H??C' 27 APril $rg anð met APri I 26 opening mee such o Co nference The 27 " at 1:00 Po lro I Apri1ourned on Wedne adj AssemblY I ra1 for the Gene P" n" that night a nd the Genera t., a Rulin g Elde r in our WYnne, S p1 ace at 7:30 the WYnne otgt 2 9, Mr" T. L. APril bn at a barbecue at th e visitors May 3, 1961" and t ribut e to oners Commissi Itisa the occasion' comml ttees ent e rta ined very de light fu.I e fficiencY of the va rious um of a was s Thi Kar¡frn an. n and to the ly wi.th a minim of Mr' L. R. Klei Proceeded Assemb abilitY General o:f the Motion Defendant's Affidavits in Support First Amended for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 100 meetofing this 196l and confusion' The ?re-AssemblY AssemblY beg an C:F{APIXR VT T T POIPOURRI A Medley of Special Frea.È;ures The facets of a church that contribi¡be'to iLs character and individuality are many and varied' So, at Highl.and Park P,resby't eri,an Church, the different activities and aspects elicit from the members reactions equally varied" One member is enthusiastic abouL Highl-and.Park's music on Sunday morning; another eagerly urges friends to come to Wednesday evening services; many visit the LLbrary regularly to study and read; a1l point to the jewel-tone stained glass windows with pride" ¡ So, a closer look at these spec:ial fea tr¡res , d,igging into their past, tracing their growth and development and includi,ng a survey of what is happening today, begins with the windows" The Stained Glass Windows When the sanctuary was originalJ-y buitt there was not sufficient money to install permanent stained glass windows,, so leaded ones with a geometric de, aign were substituted" After World War II was over, Dr" tvt" Etliott, t, ,., ,Jl" started a guiet campaign to get individual.s to pay forWilliam installing the ' planned windows and all but two were finally designed by the Wi11et Studios in 'i t: t: ì: J: 1i the more you know about them, the more will they inspire your worship ..? - ll"l:.andsanctuary. These brief descriptions and the adjoining illustration i: i' .t?.this will give you the overall conception" i l i Starting with the upper windows on the east wall near the front you see wearing a skirt of Leaves and hol ding an apple representing the fall of The lancet or panel on the r;ight shows the flaming sword of the angel of On the left i a tree symbol;ic of the temptat;ion by the serpent. As a tiibute to Dr. Thoma ss White Currie and his wife , this window was given by his ends¿ The next figure i,s Abraham, holding globe the firrnament of heaven" On the lef,h is a 'tr:ipedùhat represents the world as tent ill.ustrating his e while on the ri ght is fire on an altar reminding us of his devoby his willingne ss to sacrifice his son, Isaac. This wíndow was Mr. and Mrs. H" E" McDowell in memo¡:y o:f their son, Lie.L. Hamilton ì r Jr. next window depìcts Moses hold.i. ng ùhe stone bablets on which were i.n,ed th e Ten Commandments. On [. he left is the baby Moses hidden Ín the bullron the right the s ymbol of the burning bush" The chi,Ldren of Rulin 6b John W. Geor ge and his wife gave bhís in memory of their parents" The ndow , next Wade D uBos ' was dedicated to James Webb DuBos e, the son of Dr. and Mrs. e , whose plane was shot down over New ï rel-and" Prophet fs aiah is shown in the next window which was given in mernory lrllller Gla dney, Jr" y b his friends., Amos is the last of the Old Testaracters. in this series, He is carrying a shepherd's crook and a scroll 52 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 101 as a herdsman and a denoting his dual occupationMontgoto"ty in memory gift of Mr" u"¿ r'l'"'-W" Ray prcphet' This window of their mothers' was the Turning to the west ginning agai'n near the fro iuru aãa standing on a boo pointed to Jesus Christ as fet of friends as a tribut James, a window given bY M James, the eldest and a wa11et' Reid. st'aff o two keYs crossed, re- ed head and ca ttYing ?eter is next, shown with tonsur the office of the keYs' whictr He comrnitted Daisy M" Bargamin called our Lord's stat efn ent regarding memorY of Mrs' the to Dedicated martYr to the church on the ea rth. Mr" HowdY How atd. The of gr ft the is window s th is the coat laid dovm' a nd Mrs. Rena Evans, on the 1e ft are seen heaven; into ttP the HolY ScriPStep hen is shown gazing 1S the book of right the on and en Dr" Frank H' Kidd, bvt he men who stoned StePh window was given bY This it. uPon tures, with three stones as a tr ibute to their mot her and in m emory of their and Mrs. Roscoe Smith Susan Fisher' maternal gra ndmother, Mrs. S ara 1 of his Persecution of swo rd as a sYmbo a carrYing shown is t lancet shows the Paul, next, conve rsion. The righ own his to ior cross-hilted swo Chris t's followers Pr Bible and behind it t heshaken oPen h--the fait off his of apost le's shield viPer being the of scene the is t Given Lef the of the sPi rit; on d on the island of tvtaLta. M" E1l shiPwrecke been d ha he Dr" William into the f ire after this window i s a tribute to Mr. and Mrs" James S. ?itts, church' Jr. for his devoted service to this a Pi lgrim's s ove r the balconY, carrYing mother' real the at shown is TimothY indi cate his the two sm all figures bY ter R. M r. and Mrs. Ches and a scroll and be hind him given window was This Lois. and his grandmother , ministrY of Christ' nave are scenes frorn the the in of the windows lower The front we have the Calling of the the near e sid east the on in The subject Starting aga Lemmon gave this window" Thi s window wa Apostles. Mr. and Mrs. Mark Matthew' in reco rded as No Mountt the on rmon Se son' Lieut. George window is the their of ry memo in Earl Jackson gL ven bY Mr. and Mrs" accid ent in Okinawa în t944" a in Plane lost was who woo d Jackson, next window-the subject of th efrom is Jesus of MinistrY Samaria' Personal e Th conversat ion with the woman His and Laz, dePict scenes Martha e larg three home of MarY' the to visit His and encounter with Nicodemus Mr, and Mrs. Felix Y e must be born again," words Jesus' are all Over Jr. gave this window' e children' Jesus blessing the litt1 The Children 's Window shows in their will for this window and left moneY Mrs. John Evans Sa nduskY installed. be to one of the first ist's M deP icting Chr window a have we ar re Across the nave at the cures" Th 1 instances of PhYsical ra seve ing rat The Tra nsf of Healing i1lust Mr" P. W. Gifford, S Í. of memorY in familY center ist of, given bY his bY Matthew" I n the described ers as nt eve s that llindow dePict t he Old Testa ment charact with raiment ing dazzL in t lancets figured Chris In the lower P art of the th ree and Elias on either side" Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 102 fJ of Peter, James and John" Members of his family gave this window :in Mr. Joe E" Lawther, a Ruling Elder in this cnurch. memory of The next window, illustrating several of the parables of Jesus" was given of two charter membe¡s of this church, Mr" and Mrs. charLes sloan Teeple, by their children. The Last supper is the theme of the next window which was given in memory of Mr" James Thomas coulson, another charter member and a member of the first Board of Deacons. in memory Let's move now to the east transcept to look first at the smaller windows" First the Christian Social Action Window of the King rewarding the righteous in M is pictured one of the de of five panels t'I meatrr; me was a stranger and ye Rave t'I sick was ye visited me" ; t'I and me"; Across the bottom are the words, "And the King sha1l answer and say unto them, verily r say unto you, inasmuch as ye have done it unto one of the least of these my brethen, ye have done it unto me"r' The employees of sun oil company gsve this window in memory of Ruling xlder J. H" pressl_ey" The Women of the BibLe window was given by the l¡lomen-of-the-church and it portrays three famous characters in the Bible" on the left i,s the old restament story of Ruth, the center panel shows Dorcas and the right features priscilla, wífe of the tentmaker, Aquilae who took paul to j-ivepanel with them in Corinth" rn this transcept also are two clerestory windows" on lLhe north is the üIíndow given by Mr. and Mrs. 1f. T. Bryan., on ùhe opposite wall is a 'atthew window that depicts St' John. rn the center is the figure oi tr.r" beloved apostle, is a quill and scrol_l symbolízing his ure of an eagle, whích was his tradi_ e that was ínst:aLled at the time of gift of ínterested friends to show how completed. Shal1 we move now to t he west transcept? Here is the Reformation Window, ft in memory of Ruling Elder J, H. l-r.r,;sl¡¡-1 his friends of the Sun John t{ycl_iff, John Huss, l4artin Luther, John Calvin and John Knox the fiv e paneJ.s, l4ission Window, given b y Mr" and Mrs, J. B. ls on th e south wallTheofHome this transcept and depicts three different phases our mission work in this country. Above this is a cle restory window with the re of Luke hi¡ fri ends. in the center This window was given in m emory of Mr. J. B, peak on the north side the worrd Missions window" Thís, and the one of Mark rl above, were theisgift of Mrs. Thomas J" Jones and her family" rllustrathe severat fiet¿s ou"t""ã" in which our church has a special inleoict very lar 8e windows have so much in.brica te detail that description would to th em. The Nativity Itrs. ¡. Fred Schoellkopf,Window ,inthee asù' transcept, was the gíft of Sr" In the wes t branscept is the Crucifixion gtven by Mr. and Mrs" J" Devereaux Sm;ith" Resurrect ron the b cony.WÍndow is the ve ry Large one at .the north end of the sanc_ This window was made possible by all {on and tvas hhe members of the dedicated t o all members of this church that served in the and i.n l_oving memory of those who gave "the rast f,ur-r. measure of 54 Judgment - Page 103 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Toddie Lee WYnne ' j-stian Courage b " Chr given bY uilding herine An:ne ' u4@ !sg"l'*' erlan Hi Lan d Park Pres of rs Yea o Five e concensus of the Fi rst SEEMS to bet Although the His bo C€r ee k Serv aM on Church makes no ment has alwaYs been a Prayer me eting. " olT5" that "there he-Bible Reading Hour' Through-t have Bible rvice, Se the mid-w eek services rs appea it PraYer Meeting' Mid-Week the since r name it wa s called, rough the Yea rs wors hi.p all th Course t or bY whateve of s hour the rnost helPful been one of church was first org anized in MaY t926, ' I ; had been n there of the church' whe life the of rs chool houser the s a we re held in During th e first few Yea services ions of some inand Sunda Y Recollect A, no house of worship built, mid-we ek services' fot members' Mrs" Dan reLace earlY P other the of some She ha d to be some various homes" the Lewis have come from teresting experiences ?raYe r Meeting be ing held in the oft en held in the services were T empleton ( great aunt English t ells of the time that o f ALlison she members that during Part CarPen ter's mother, Mrs. hiP' In orde r that to. Mrs" broken a home. th wi T. CarPe nter home services to the brou ght the services, theY (the of Mrs" English) wa s confined evening int e rim pa sto r WednesdaY D r"E,C.S cott might be able to enjoY lead the ed the Piano; volCe and would her" Mrs" CarPenter PlaY Pa storr came) h ad a sPlendid be about twentY-f ive in Dr" Alexander, the first tha t there would diff erent Jones remembers be held in several Wurtem Mr. woirld ices si.nging. serv even ing s and ek. He exP ressed the each home on WednesdaY would 1 ead some of them each we force in the earlY da a Powerfu 1 a ne1 ghborhoods. Elders er meetings we reworrld PraY home ese often be the Pla ce for th that s BoYd opi nion of the HarrY of the church" The home were often WednesdaY services the at927, in coming A lexander on After Dr. Alexander's by a lesson bY Dr. Dr" fclllowed evening bY an elder t that one W ednesdaY worshiP serv ice led GraY remembers Joe At this time se s Mis Beard.tt ronts criPture. s of Aa passage rather thr Oil that Ran Down st floor room e, ld. fi'r a room, Alexander's topic was "The ment were h Junior DePart víces were held in the where SundaY se rvices floor, second the only Alexander Hal1, on ( Lg32-r937) he came the pastor ly suPP and was e I¡I' Cu rrie gh Mrs" Cr¡rri When Dr. Thomas week in Au stin, althoutha t Mrs" Currie he t sPending SundaY serv ices, Kle in recalls t Mr. L. R" Da1las' in leading PraYer Mee Meeting' ed liv ttpa f children sto t " even being PraYer the we ek r often led the of her time duringremember s Pâ Mr " Joe Lawthe that during Dr' Curriet er eda minist necessa ry' Some stant explain assi had be the Ludwell Da vis came to tha t at one service, aft er Mr' Davis e sPoke uP a nd s¡ Miss Joe GraY recalls eight- or nine -yea r-old Stuart Curri Misses Joe oPinion" passage of sc ripture, .tt and gav e his of these WednesdaY t'But , Mr. Dav is, Father saYs' its b enef great the of one fellow shiP that close bhe was Mattie GraY s ay theY feel daYs of the chrrrch y services in t he earl bers. mern aßong those there we îe ocÇa! comPleted' was d-week kitchen with featu re for mr emi ar tegul After the new buildirÈ a as not th that d be served, but the reco rds shorry when a dinner woul 2) This (L935-L94 came study"" and Bi b1e vices" After Dr' DuBose inner for "d evening, service was on Thur sdaY {r i Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 104 55 was chosen because it was "maid,s nig chi.ldren. M¡s" George R" Al1en remem cents, three for one dollar" She reca instead of the women of the congregati The fírst Thursday evening the cai.eres week it was very poor. Mrs" Clyde Ben .tíon, was to prepare it the f'ollowring good stuffed pork chops as Mrs" Bennet Lawther, Mrs" Harriet Mott, Mrs. fsabe the members who had charge of the kitc a hostess was placed on the regular st long these dinner meetings on Thursday day Prayer Meeting at g:00 p.m," in Oc The church was without a regular pastor from December L942 until February Dr" Elliott came" During this time Dr. Donatd G, Miller was assistant pastor and he and other men of the church held ,,Mid_week service for ' Prayer and Bible study" " rn January L943 the evening was changed from Thurs' day to wednesday, without dinner , and has remaì.ned on Ì{ednesday since that time. On Wednesday, Februar y 23, 1944 a fellowshi p dinner held for Dr. and M¡s. Elliott. Three hundre d and fifty attended, At lhis was dinner meeting Dr^ Elliott said, "Mid-week ser vices will be devoted to Bible teaching" Every effort will be made to keep thís service,interes ting and vital and within the proper length of time"" He indicated the n ame "Prayer Meeting'r would be better replaced with some other , and Mid-Week Bibl e Hour seems to have cau ght on at Ithat time and has been u sed, with slight va riaLions up t:o the prese nt time" It ls evident that Dr. El 1iott started the new Mid'-Week Bible Hour with lectures books of the Bible for in March we find erencìe f,r¡ !t,l.sf lecture on Book of with the added commen.t: "We a ¡îe confref ident tha b you wJ,ll enjoy these i.n,_ gatherings and tha,t you wil"l be great.ly hel.ped by Dr" ElLiobt's popular lectu res o " In the copy of the church paper for i;he fo,llowing week we read, trFrom wh at we have wi.tnes sed of the attenda¡rce a nd inte¡est at these meetings, it'looks as if this Mict -lt¡eek 3;ible IIour is.3oing to be one of the most popuJ.ar tures of our church progra tÌheld in what was a t that -Come*,-'7:: 45, Bring your Bible"', The services t ime Alexander Chapel on t:he se cond floor of the Education Building, 1944 when In the fall f , after studying separate bocks of, the Bible each week, ser:tes was changed to a series on "What the presbyterian Church Believes ches about B aptism and and the Lord's Supper"" The¡,e was also one lecture on f ed P¡¿ yg a. rr o L944 ring the spr ing and summer of L945 Old Tesùament characters were s tudi ed also a ser ies on Doctrinal "Some Teachings of Jesus," In April 1945 " h paper ¡¿¿ the following an nouncement:: In the future I Even ing pre will be services, As a part of the new pLan,there will be la id upaching increased em_ on our Mid-lrreek Bible Þular wi th our people and it isHo ur. This teach.i.ng service is a1_ devot e d to rhat with more time and it, it can easily become on believed reek a no many e of the most cherished services mo re will want to share i n it," nB the summel , different orga nizations--couples class, choir etc" -,8Pons6.. for the mid-week , servic e? encouragÍng aLtendance and sharing ssr Fol1o wrng in the policy of varying t;he subject eome of rna.tter of mid'-week t he more t standing topics used during rables of JeSUS,rt ou bhe next several years rrT saiah rt, Lectures on Japan,r (after Dr E1l-io Ët 's to the Mi ssion Fie Lds), ùpÊrciai series on Miss ions, ser:ies 56 Judgment - Page 105 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 106 t' I hrist's Message to the Seven Churches of erianism,t' "Perscn. and Work of the Holy eak T'oday, " "Old Temptations in New f Christr" "PÊber, the Most Unforgettable s i-n ùhe Old Testament and Pr:ayers in the Paul," "Calvinism,t' The Probestant's Deasions when Dr" Elliott was out of the cted the mid*''n¡eek services" Interspersed ecial events, heJ-d on Wednesrlay evenings, er L946, Mrs" Joe E" Lawther was employed vice" It was customary for the chancel. choir to ftrrnish music for the lrlednesday evening services sometimes assisted by the youth choir" On one occasion the presented an evening of worship through Negro Spirituals" The attendance "t,oir this time was two hundred and f).fty to three hundred and fifty" Before áuringair-cãnditioned Currie Ha11 was built (1951) during the summer months mid-week s"ruic"s were held on the lawn just outside the East door of the Narthex" These outdoor meetings attracted large audiences. have had many distinguished speakers on Wednesday evenings, among them Dr" S. L. Joekel, September L946i Dr. Frank Brown and l4rs" H" D" Haberyan in January, 1-948; Dr" Robert H" Bullock, August, L948; Dr" F" Crosley l4organ in October L949i Dr. Louis H" Evans in October 1951; Dr" John S" Bonnell in April 1953; Dr. Norman Dunning in Matcln L954, and many of or¡r missi.onaries who were home on furlough" We In October 1950 there was a seråes of five lessons on "My Christian Be1iefs." Credit could be received from the church's Department of Leadership Education in Richmond and out of an average attendance of 2L3, fifty-four credits were issued" In February 195L, Dr, Elliott offered "studies of Favorite Bible as chosen by the congregation. This stimulated much inte¡est" Passages" 5, 1951 there began, with Genesis, the three-year study known as 'tThrough-the-Bibl-e Reading Courser* with Bible reatlings assigned and mimeographed outlines distributed with blre study of each book. Thís was a one-hour Lesson. The capacity of Currie Ha1l was taxed wíth an average of 400 the first three lÍednesday evenings. The interest was so high that no interruptíon was nade in the summer months. This reading course cr:ntinued until February1955, with only a few interruptions for special speakers or for family night or congregational December dinners. At the beginning of 1955, various organizations of the church, such as Couples C1ass, WestmiÃster, Currie, Elliott classes were responsible for stimulating atten¿ancå. A concerted effort was made to i.mprove congregational participation. The Women-of-the-Church served as hostess each first lalednesday of the month and following services sponsored a social hour with refreshments served. A goal of 400 was set for attendance at a new series beginning Febtuary 23,1955': "Six Studies Based on Westminster Shorter Catechism"' This series attracted a large attendance. Following ,this, special programs were offered for several weeks, pertaining to growth ãnd develäpment àf cnr¡."tian FamiLy Life" There were family-centered movies, discussions, exhibits of books and pamphLets and a chalk talk by Mr. Torger Thompson with Miss Louise McComb as narrator. 58 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 107 Duri'ngthesummeroflg55,Dr.Elliottdiscussed,,someRecenlQ,uesti<lns: Faith Heaf ing?"' etc" the Trinily?, Heaven?, HåfU, Sunday Observarrce? ' What Abo,ut Various interesting subjects were p frebrua ry L957 when the Wednesday evening pu.rpose was to make Wednesday n:ight a chu was served a't reasonable prices so that w of Christian Ed.uca'tion, laymen, våsiting the various classes, where there would b fi.rst week 782 were present, the second stabed, *'The new Church Night Program ex committee in charge. The mid-week seri Mrs. Edna Walker was now Church Ho musìcal treat came for the services when Ray Matson at t'he piano would lead the c var church. Since the initiation of the progr general the been dinners, this has classes have brought to these studies no church but other outstanding teachers' a Ashby Johnson, Dr" James R" Thompson of have also heard Dr. John Finley Williams on experiences of a Christian layman in Wi.tliam B" Oglesby, Jr", Professor of Pa and H'eal'ttt' Seminary i.n nicÀmååa, vÍ.tgi"ia spoke on Religíon serres' "'Great Nights of In June and July of 1958, Dro Elliott announced a theBibl-er"andgavet'heto"gt"gutio"oopottu"ltvtosuggesbotner'"GreatNightsil for study. repeaued his series on BY PoPular request, in APril 1960, Dr. Elliott "Questions PeoPle Ask"t' For the second time a "Through*the September 21, 1960" Supper preceded the urrã fifty cents for children. At the fi sanctuary. There was an expanded progra 'tion as well as activities. Program for WednesdaY of 19ó1, Dr" Elliott oPened the fall- triP to Western EuroPe hi s recent even]- ngs by showing slides and lecturing on er and "T'hrough-thed,inn o and B ritish Isles" The following week the six 'clock gave an illusott 1i El Dr" Bible Reading Course " resumed. On Janual'Ì 3, L962tslid es from his triP the with trate d Lecture on Denmark, Holland and France the Drama group P resented the Easter before WednesdaY one On summe r before. Reading vs" Pontius Pilate. The "Through-the -Bible qLAY, The Case of Humani ra ct ing 8OO particiPants" Cours e resumed n Septe er L962 and was a tt in the 'f aLL af L963, Dr' Because of the initiating of the C.L"C' studies in l:he World is this Elliott gave three Wednesday evenings to the subject' "What c.L.c, ?" tn 59 Sep tember Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 108 The "Through-the-Bible Reading Course" concluded on December 30, L964. The first two Wednesday evening meetings of 1965 were of unusual nature" presented a revie and on January 6, Mrs. V. Y" Rejebian drama, a by Ibsen, sponsored Thesbyterians the 13, January This in Bishop's Company. played by the was which offered. drama for sanctuaries. On JanuarY 20, the elect Study, Bible Church Doctiine, Relations, offering Famil-y classes seven were There Studies in Three and Foreign Missions. Park Church, of Highland On-Going the during the offered spring" were courses elective of series The fall program for 1965 began with illustrated lectures by Dr. Elliott, and Mrs. Ell-iott's travels in Egypt, Lebanon, Syria, Jordan, Israel, his on Greece, It,aLy and Scotland. These were cornpleted in January" On February 9, in the sanctuary, as a contribution to the drama ministry in our church, the Thesbvterians presented the drama, Family Portrait. During the spring two series oi elective courses were offered. In May, after Dr. Elliott's attendance at General Assembly in Montreat, North Carol-ína, he used one Wednesday evening for a lecture on "Proceedings and Actions of General Assembly"r? Another mid-week service was a study of the stained glass windows in our sanctuary. The slides were made by Mr. Theo E. Jones with conmentary by Mrs. Mardi Jones, The summer program consisted of novies every other Tlednesday evening, chosen for family viewing" Although the rnid-week services have served as "refueling stations between not been devoted altogether to study" This was a favorite time for recognizing those who have served the church faithfully for long periods of time" Such were the happy occasions when Mr" Abe Mathis, one of our Sextons, was honored for his long, faithful service to the church" On another Wednesday, Mrs. Limma l¡lallace was presented an orchid in recognition of her twenty years of faithful service in the Food Service Department" Other social occasions were receptíons for retiring staff members, or those going to other fields of service. These receptions were held after the lVednesday evening services. Those honored were Miss Louise McComb, Dt. and Mrs" Arthur V" Boand andMrs. Ralph W. Howe" As new ministers came to the church, they and their families were honored at receptions on lrlednesday evenings. Sundays" they have Thus over the years since Highland Park Presbyterian Church was organized, the mid-week services have truly been a School for Christian Living. The Chancel Choir The Highland Park Presbyterian Church Choir was first organized in L927 " At that time the congregation was holding its services in the Highland Park High School (now the Junior High School). Mrs. Howard (Mary) Beasley was the first Pianist-Director and she was followed by Joe Murray who was Director for a short time, In the church bulletin of October 5, 1930 was this announcement: "Orr reports that they have secured Mr" Xarl- Jackson as 'Director' of our choir. Mr. Jackson has had wide experience which thoroughly equips him for hls new position and we welcome him heartily in our midst"" Earl Jackson had directed the choir at Gaston Avenue Baptist Church for five years and Grace Nlethodist for two years. music committee Although the choir was sma11 and made up of volunteers it did possess wonderful talent, It is interesting to note who was in the choir on the 60 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 109 occasion of the Christmas program g:iven Decembe c 27, 1930" @.* Mrs. Mrs" J" ¡¡ c" E. HotTfman, Cumby, Mrs. GwYnne Curtis, Mrs" J" T. Hardee, Mrs. F" G. SEamp.ley, B. Mrs" H. Hudson, Miss Genev ieve Hudson, Mrs. J. T" Plangman, Mrs" Mrs" C" Lawther, L" Dean Mathis and Mrs " liiri¡'rlç:¡rr Jones" .4lbos: Mrs" Joe E. McCarroll, Paul Rev" McNulty and Mrs" Ruth Parks" Tenors: Mr" R" W" Ilolve, Mr. Wilkin, George Mr. Jr", A. Wìlson, R. Mr. Sr", R. A. Wilson, E. C" Scott, Mr. Mr" Fred Varker and Mr" Earl Jackson. Basses: Mr. Dan English, Mr'. t" 5" Helmr Mr. WaLter Hogg, Mr" T" P. Junkin and Mr. Hugh Johnson. Mr. Jackson's tenure as choir director was from 1930 until 1939--nine imcourse, ?ll portant years of growth for our church. The chu rch services were, of month, a was $50"00 and in the Alexander Building, Mr" Jackson's highes t sal.arywas to uP the Brand t d Pianist Harol Mrs" monthly. the pianist received $25.00 l''lrs, time that At Houston. to moved family Brand in the late '30's when the Arthur Harris succeeded Mrs. Brand as pianist" Dr" Thornas Mr. Jackson served under three ministers: Dr" W. A. Alexander,grew both choir the period, W, Currie, and Dr" Henry Wade DuBose. During t his as names H" bY such in numbers and in quaLity' The choir roll was increased HarrY Blocker, Jr",C. Bassett, Harry Barton, Mr. and Mrs. HarrY Blocker, Sr" and(Kathryn) ElLison, Mrs. Nel1 and Stanley Bowles, M rs. Perry Carro11, Mrs. Marvin (Kathleen) Melvin (Gertrude) Garrett, Mrs. C. .E" (June) Granger, Ivlrs" Gordon Mr" and Mrs. H. L" Dr' Quinn, Johnson, Mrs. Dan (Princes s) O'Conne11, Ruby and Pl-owden Vick Stubblefield, Marcus and Dorothy orey, St Boude Mrs. Shimer, John and Mrs. Murphy Williams. As a pleasant sidelight, it is interesting to know bhab our present (then Associate Minister, Dr. L. McD. Kennedy and his sweet wife, Betty days" Betty those during spencer) met and started their courtship in the choir mensoloists during those years--in addition to those members already of Several Tool' A,lbert tioned--were Mrs. E" H. Blum, lrlalter Hogg, and Mrs. gave their but choirs church these fine singers had been paid singers-in other services to our church volunta tíLy " thís As evidence of the quality of our choir frorn the beginning we quote 1edbe again to opportunity "We welcome this i,tem in a L932 church bulletin: of their in worship by our splendid choir. lve express to them our appfeciationLord"' the to devotion their and faithful and effective work in this church the Letters to Earl Jackson from the first two ministers further attest both AlexanDr' of 1931 spring the In choir. of the worth and enthusiastic approval of the der wrote in part: "I am volunteering a word of deepest appreciation after the me told us with worshipping was who man work of our choir" A BaptíSt While service that it was the best choir he had heard in the city of Da11as. yesterday, a llady who is a member of another Presbyterian church, expressed Her question amazement that the choir was made qp of members of our own Church' that prayer tt is my earnest was, ',Are every one of them paid singers?' tha.t feel the choir may find great enjoyment in their work, ar¡d that they mays€rvice"r theirs is a most ¿iitinct and valuable contribution to our worship And later Dr. Currie wrote: "Of all the choirs that I have ever been privileged to know, I rea11y believe from my heart that we have the most my gloríous one" You people as a group and as índividuals warm my heart beyond such in and ability to describe. Everything is done so well and so beautifully I think it a fl"ne spirit that f find the choir a constant inspiration to me' rnuch to bhe was especially lovely for the group of you to come out and add so Men's meetíng last Monday night." 61 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 110 director, Mr. Arthur Harris and his st. It was at this ti'me the first paid : Louise Mackay (soprano), DorothY ) and Austin Watson (tenor). This ices and on Sunday night and for the ir. They were paid $12"00 a month eachj ew 1 Dorothy Hal-l, the a1-to soloist, decided the strain of practicing and at much for her and soon resigned. times of singing a solo was a little too joined the choir and took her place soprano, mezzo lovely ,rär'rtr, Temple Smith, ever had' we have ,, on" of the finest soloists Choir practice was held in one of the Sunday School rooms. Although our Mr. Harris was trying to build ahoi,' was very smaLl it was very conscientious. into the new sanctvaty, which be noving i"tirg"t singing group as we would soon ."rr at this time under construction. ,.' ,, i , the choir moved into our beautiful new sanctuary where we were proud to sing amidst the gracious majesty of this great church, the choir soon began to grow. Mr. and Mrs. Harris moved to another city and we were again without a director. However, a young man, Mr. BíL1 Trígg, took over for about six months' Then, in 1945, Mr. Ralph Ewing became director, stayed a Year, after which Mr' Roberts became director. He remained about a year and a haLf" When After Mr. Roberts' departure, Mr. John Bumstead was engaged on a temporary basis (he stayed five yearsj) and things rea1ly began to pick up in the choir. Not only was Mr. Bumstead an outstanding singer but he had quite a talent for organízatíon and many young people began to join the choir" It was during this time that the choir started to make public appearances". They sang on radio on numerous occasions arid supplied other churches with soloists and quartets. Splendid programs were rendered at the dedicatiorsof three sister churches--Westminster Presbyterian, Park Cities Baptist and University Park Methodist churches. Music was furnished for funerals, weddings and various church meetings. It was in 1945 that the choir became a real organízation when it elected its first officers to a one-year tern, subject to renewal, Presidents in chronological order were as follows: Austin Watson Mable Muse O. M. Stubblefield Jim Muse Bill Britt L. H. Bohmfalk John Boynton Kenneth OLson L945-46 L947-48 L948-49 1950-51 L95L-52 L952-53 1954-55 L9s6-57 Dudley Penick 1957-5 Jackie 19s9-60 DeSalme 8 Glen Ford 1"960-61 Tom Losey L962-63 L963-64 L964-6s 1965-66 1967-6 8 llerle Arnold Emmet Schayat Shirley Christensen Dr. Ed Harrison A constitution and by-laws for the chancel choir was prepared by John Boynton and adopted. In 1950, included in the building phase with Wynne Chapel' was a new choir roon, given by Mrs. Toddie Lee Wynne and named the lmogene Wynne choir room. She gave this beautiful room, a room with unsurpassed furnishings, so 62 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 111 .''',?Î that the choir might have a better place bo prepare ,its music" On the _Sunday thisi room was dedicateã, a beautiful scro11, signed by each member, was read and presented to Mrs" Wynne" This scroll was designed and written by a talented choir ". The carpet, drapes and lamps were a11.carefully member, Mr. O. M" Stufflefield, selected by the donor which contributed even further to the choir's pride in the beautiful room" As the choir grew and became more sure of itseJ.f, Mr" Bumstead suggested by the that an album of sacred music be recorded" This proposition was approvedone in carries Graham Billy Dr. church congregation and was guite successful, Norvell Mr" on sung and played his collection and many times the records are Slaterts program, t'Hymns we Love" on WFAA radi'c, Tn L952 Mr. Tom Merriman became our director" He was very well Liked by thS he is an choir not only because he was and is a great artist himself but because also to have was choir the fortunate accomplished teacher and instructor" Hãw each tirn" everyone "he thrilled voice Mrs. Joan Merriman whose glorious soprano would solo and sing duets with her husband. Through the years, the choir was acquíred a wonderful repertoire in music: THE MESSIAH bY Handel ELIJAH bY Mendelssohn STABAT MATER bY Rossini THE CRXATION bY HaYden SEVEN IAST WORDS bY Du Bois" These are just a few among the marvelous masterpieces that the presented" ch While Mr. Merriman was director, Mr" A1len Jones was a meml, i ùi the choir. Soon after his graduation from SMU, he went directly to Hollyir.rod and has become quite famous as a television and stage star. He changed his name to A1len Case' After Mr. Merriman left our choir, Mr" William Tagg became our director. It was under his dírection that our choir did one of its most outstanding works, KIIG DAVID by Arthur Honneger, This was presented at McFarlin Auditorium on the Southern Methodist University campus. The choir was accompanied by members -of the Da1las Symphony Orchestra and the church string orchestra. Dr' Lloyd Pfautsch choral director at SMU, narrated the story of David as he did for the Robert Shaw Chorale in the Carnegie Hall debut of this oratorio" After Mr. Tagg's resignation, Mr. Devon Hamilton came from Fort Worth to be our director in August 1965. Mr. Hamilton is an accomplished director and singer' He and his wife have three lovely children" Many wonderful people have been and are i,n our choir'. The whole membership of HppC is tremenaousiy proua of the wonderful, music we hear on Sunday and would like for each person to realize we know he is an important part of the choir organization. Mrs. Jqhn Boynton, a long*time choir member, declares that if these fine members at some time feel unheral-ded, they need not; indeed, they are the very foundation, nucleus and backbone of any fine church choir. ChiLdren's and Youth Choirs "With happy voices ringíng' Thy children, Lord, appear; 63 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 112 Their jo'yous praises brínging Anthems sweet and c.Lear. tl youth choirs have long been a part of Highland Park Presbyterian Church, â1been able to find records before L946, when Mrs' Sam Parker lhough we have-not ã¡.t".tor of the Senior High Choir' "u" "#s* t947 to L952' During the time that John Bumstead was Minister of Mus:ic, from (Ruth) Lansche, Mrs. Peter Dimitriades directors oã youttl choirs were Mrs" Parker, the choirs" lrã. *r". Craig (nutt¡ Sowe11) uirtis. ',vho also accompanied Mr. Bumstead otganlzed. a Boys' Choir, which sang for weddings, at the progfams. In 1951 Ruth Lansche moved to Neiman-Marcus Exposition, and at church with the ,iã"'t"rt Cì,ty, where she continued her work with youth choirs and sang Metropolitan OPera ComPanY' l¡lhen Tom Merriman was Director of Music (L952-L959), Ruth l4i11is continued accompanist. During the summer, Mrs. William (linter) Rautenberg assisted as -.--r isyouth Choirs and has continued as director, accompanist, and choir mother. i\lrs. J. J. (Janet) Jerome, daughter of Federal Lee Whittlesey, who ,rf Music at Highland Park Methodist Church, became director of our youth vr,.¡ì1s. When she took a leave of absence in L956 to have a baby, Mrs' returned and' reÀnne Brown directed the Youth Choirs for several months. Janet Shirrlett a nd i"'ã¿-r'" i ":'n. ï:' In 19-54, 1* I :i:.:å' î;: ï:lil åffi r::'1""'rrt7'l;oÏälå.'""v c-",,n 1959 to 1965 Williarn Tagg was Director of Music, and John C" Cooper ;cted the Crusader Choir (Youth ðnoir), with Barbara Porth as accompanist" worship under Mr. Cooper,s leadership, the crusader choir participated in Sunday on tour' gave conCerts and services, special services, appeared on television, chaperones' parents as several In the summer of 1965, with the R. Earl Prices and they toured the southårn part of the United States, incl-uding performances at the St. Charles presbyterian Church in New Orleans (Dr. Boand was Supply Pastor), and the Druid Hi11s Presbyterian Church ofAtlanta, where Dr. Elliott was formerly pastor. The choir collected tons of paper and sold many pounds of candy to help finance the tour. In 1960 Mrs. Gerald (Nita) Lumsden became supervisor of ChiLdren's Choirs' The several choirs for children five yeafs of age through the sixth grade were directed by Nan Soden (8i11 Tagg's assistant), Carol Tagg, Nita Lumsden, and Bill Tagg. Mrs. l¡lalter (Cecile) King was chairman of the Choir Mothers'Guild' with a staff of tireless and devoted choir mothers. Succeeding choir directors were Mrs. L. L. (pat) Coggan, Mrs. George (¡¡ary Margaret) Sullívan, I'lrs- William L" (Patsy) Hutchison , nátara Porth, Mrs. A, C. (Barbara) Soukup, Jt", Mrs' James N. (Jeanne) Stil1áan, and Robert J. E. Hughes, who was also liir" Tagg's assistant' During the yea¡s that Mr. Tagg was Director of Music, the children's and youth choirs performed at Sunday aÁá special worship services ano participated ln city-wi¿" cnifaren's choir festivaLs as members of the Choristers Guild, a nationa L otganLzation whose headquarters are in DaLlas. Our church was host to one of the festivals in February, L965, when Jane Marshal1, well known composerdirector, conducted the mass choirs. In L964, while Mrs. Ralph W. Shaw was chairman of the Choir Motbers' Guild, 175 new robes were made for the children's choirs. They were patterned after the Crusader Choir,s new robes--black skirts under a full white surplíce" Making the robes involved the generous cooperation of nea fly 2OO people: Mrs" 64 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 113 Shaw; Mrs. George R. Allen, Sr,, chairrnan of the Christian Projects Committee of the Women-of-the-Church; Mrs. R. Xarl Price; and mothers of the children inDaythe choirs" The first occasion to wear the new robes was at the Thanksgiving worship service" From the fal1 of 1965 until the present, Devon Hamilton has been Director of Music" Mrs" Lumsden has continued as Supervisor of ChÍldren's Choirs with Carol Hawkins, Mrs. Lynwood (¡¿na) Butler, Mrs" Devon (Marlene) Hamilton, Mrs" c" P. (Jean) Hatton, and Mr. Joey Evans as current directors of the children's choirs. During this time a new Boys'choir has been formed, a three octave set of Schulmerich handbells has been purchased, and three handbelL choirs have been orga nized, wii.h the scu':' Easter, Advent, choirs perfonning at 8:30 worship services, ,luring Thanksgiving, and other special services. The format of the choir program has been altered slightly, In October, 196ó, Mrs. Mabel Stewart Boyter, leading authority on children's choirs, spent three inspiring days with us, conducting a choir workshop? ended in an evening concert. I ecorder The severaL children's choirs (vocal and handbell) a¡ r year" I choir choir presented a concert of hymns and anthems to end the 1v. thi.s ''1 C .¡rs' l4c'i ttrs. E" Eugene (Anne) Uecker has been chairman of the Choir time.' thei': of year. An endless list of mothers have given generously Junior High youth choir activities have continued, Il'ith the additio' Crusa the conduc[s also It is directed by Mr. Hamilton, who Girls'Choir" Choir with Joey Evans' assistance. ? Both choirs perform at Sunday morning and special worship services" youth c''''il the with fell-owship of musical Crusader Choir has enjoyed an exchange of the First Presbyteiian Churcir of óttanoma City, where John Kemp is Director of Music. ", rrìtf :# #t Foreign Missions Throughout her history Highland Park Presbyterian Church has been a missionrninded church with a desire to show her love for Christ's world and its people by contributing on an ever-increasing scale to this world enterprise. Even in our early days, when struggLing with the finances of a young church, an arnount was always contributed to míssions" Thus we find that in the years L926-27, the ,*ouÅt of $2Z6.00 was given; the next year this was more than doubled with a gift of $722.00, and so on through the years steady progress has been made" Our 1965 pledge showed the sum of $72,337.00. Also during these years we have as a church or in some cases as inoividuals assumed full or partial support of some thirty-one missionaries. As far back as LgZ8, Miss Katherine Gray in Mexico and Dr" and Mrs" M" P. Young in China were on our roster of missionaries. Not until 1945 did we increase this number, then adding Virginia and Bill Pruitt, So on through the years the list has been added to or changed on account of resignations or !.eaving the field for reasons of health. In addition to this list of missionaries whose support has been contríbuted to by the church as a whole, ten others received entire or partial support from members of Highland Park Presbyterian Church" During the years nehl names and new faces have appeared among those we term "our missionaries" and always we have been richly blessed by our contacts with them. It ís with special pride that we 4oJe the presence of our List of several from our own congregation" o5 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 114 I s received constant encouragement in rough their sermons, their helP in s, and their bringing, in some cases' was with pride that our participatio-n d Chairman of the ,Assembly's Board of r mission fields made us more a part of on october 6, L963 through the 9th, HPPC was host'üo the world Missions Jr., at the time President of the Men-of-thethe Conferenced He presented to Dr" ãn"r"n, was in charge of artangements for ating hís 25 years of service as a memions. Dr. Elliott handed to Dr. C. Darby Board of World MÍssions, a check for conference. Mr. Brookin N. wadley, an Church--this constituted the World n the Presbyterian Development Fund canpaign. H?pC's interest in the mission field does not include from various Sunday School classes gifts made by the lrlomen-of-the-Church or those present fully the ínterest ín the to ãn¿ departments. It would be impossible that the dollars given, the ¡ conviction hearts of many of our members or the dee investment that in fruitful been a in the cause of missions, have iiuu" spent ,.r, cod,s nrovidence will never be lost. Certainly it is our believing ' and gifts' our hospitality to foreign students and to part of some of mlssaonarr-es on furl.:ugh, and the gift ãf tit"'and ski1l on the have placed our doctors--surely, ii is these cóntributions fro¡n the heart that the Hiehland Park Pres6yterian Church alongside those countless ones who through and rr1 and heeded christ's command, "Go ye into all the world preach the gospel to ev":ry creature.'r i¡¡i. ,,,ef, review of TaIk Presbyterian Newsletter Dr. William M. Elliott, Jt., who came to Highland Park Presbyterian Church as senior Pastor ín L944, was founder and first editor of My church" of the dhen I came to Dallas our people were receiving each week a copy front on the news Pâg€"' church Dallas World, a rather large ,r"""pupèt with some should that publication of kind said Dr. ELliott. "I felt that tit¿s "a" not the a good requiring was it furthermore be getting into the hands of the people, and people of the some to In talking deal of time to furnish copy for ¡.t eactr week. people I found that about the onfy'service which this communication gave to our perasked üherefore f Sundayj was who was to preach the following MY CHURCH (Highland to tell them missiontocreatesomeothermediumandconceivedtheideaofourpfeSent@. I named it and also edited it myself for quite some tine.'o Dr. Elliott's first pastor's Letter in the first íssue of My Church (dated October, L944) said, in part: t'Dea r Friends : Hereisthefirstissueof@'anewpub1icationwhichhasbeen to your home once each month' lfe approved by the Session and whichli-ñe bring to you each month Chyrch-wil1 My hope you lite ttre idea and the format"life' announcements of imporõì¡r-Gh of phases iniormation about the various the u¡orld ' anð' throughout church Christian thà tant coming events, news of of contact with our form that this feel We articles. stimulatini and quotations 66 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 115 Æ E rapidly growing membership will mean much to our church, and we urge you to read :;]{ i This first issue (dated October, Lg44) had a column named "Parish Notes" October meet- :;Ì with 1itt1e items of interest such as."'Dr, Elliott will attend theTennessee, in Nashville, .,i ing of the Executive Committee of Foreign Missions October 9 and 10" and "During August aná September we received 37 new members :"i There were into our church. . Our present membership now stands a'l 2'242"" month (this ii each Contact of copy articles about our members in service receiving a II that i,. Wa¡ World affig was it was a good service then as well as presently, ãnd under Scouts Boy lþs : 80 Troop the 1944 Contacts were being sent from HPPC); about Bible Lecmid-week Elliott's i"a¿"."ttipiffiutmaster Dãe Downs; and about Dr" ",' tures on II Peter at 8:00 P.m. .: Dr. Elliott, founder and first edítor of My Church, edì'ted the monthly untif i' Park as Assistant Pasto¡ 'i Dr. L, McD. Kennedy (then, Mr. Kennedy) came t"Ìi-îã :i: in L946o Dr. Kennedy edited the newsletter untíl 1948" There is a gap between t 1948 and 1950 where it is believed that Dr" Elliott continued supervisíng the i,l editing of the newsletter. Then, in January, t95O' Mr. John Bumstead beãame t full.-time staff member (Minister of Music and Lay Assistant) and it was announced that Mr. Bumstead was editor of UI Church. When tutr" Sumstead Íe;ft his HP?C staff ,,. iuy¡¡ur,) was given the title of position in L952, Mr" W. ff. flptofffifplð "volunteer editor-in-chief" in October, L952" Mr" Tipton Àerved until September, L953, when he was transferred to another city" Dr' Arthur V. Boand, who became Associate Pastor at HPPC November 1' L950 ' supervised and edited trly ðhurch from 1950 until 1953. During this time Mr' Walter lrlest, Church Business ffi"ag"+ also helped edit My Church until he left the HPPC staffinSeptember,1955"Butthere"al,,o,.^ffi..ititt.,''Editor,''unti1 in later. Dr. Boand's poems were especially enjoyed items that appeared the issues of My Church from time to time' ' , Reverend Robert L. Ferguson came to Highland Park Presbyterian Church in L95T and was announced as editor of the newsletter in September 1, L957. There was a significant change in the looks of My Church during Mr" Ferguson's tenure' changes started in the A1so, My Church starteã coming out twice;lñõnt'tboth 1958 issue" January 2, Next editor was the Reverend Robert G. McGehee, Assistant Pastor, who came to ÉIPPC in April, 1960, and who was assisted by Mrs" Lynn V" Lawther (Associate Editor) throughout most of his pastorate here. Mrs. Lawther continued as Associate Xditor when Reverend R. Earl Price became Editor in October,- L963' the date Mr" price became an Associate Minister at HPPC. Mrs" Lawther served as Associate Edito¡ until January 15, Lg64, when Miss Nanette Geeo became Assistant Editor and secretary to Mr. Price. The Church Library -tssl-1e6ó- From t'he beginning our Church has placed emphasis not only on growth in members but on growth in all the areas of Christian education that might encourage its members to become spiritually strong. It seemed natural that in the realm of growth in Christian character and conviction, a Church Library could best serve all ages of our Church famí1y through the ministty of books. During the sumner of L952, our Director of Christian Education, Miss Louise McComb, asked Mrs" W; H. Tipton to assist in collecting, classifying and' catatogíng o1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 116 church school, This books that had previously been kept in departments of bhe work 1ai¿ the foundation for a Church Library' In 1953 the Christian Education Committee appointed three members, Mrs. first Library Henry Inge, Mrs. Roy Taylor , and Mrs. Carlton Reed, to form the with ðorrl:tt"", to serve as a sub-committee of bhe Christian Education Cômmittee a stated budget. The Library began in the office of Miss McComb, then moved ínto a sma,ll room Mrs. ín the Educational Building. As interest grew volunteers were added with the as *, S. Kennedy serving as the first secretary and Mrs. Shannon Bertrand first treasurer" In 1956 the Library moved in with the ltlomen's Bible Class, Room 104, which it shared with two classes each Sunday morning and many groups during theofweek' usBooks and visitors increased and so many requests came for the privilege through its use schedul-e necessary to became it that meetings for Library ing tfre the Church Office. The Library remained in Room 104 until an additi.onal building program was begun in L964, wiren it was moved to the Youth Building. As work on the church neãred completion the Llbrary was assigned to a permanent place in the Education Building. Here, in a room which our Church School has bearrtifully furnished and to which so many inoividual gifts and memorials have added charm and interest, our Library begins a new era. It is not possible to mention all the areas in which the Library has served, but a few should be remembered. Beginning with a desire to instill in little children an early love of good books, tñe "Stóry Hour" was begun in 1954. This project was under the supervision of Mrs. Hâro1d Corey and Mrs. W. C. Gipe, who worked with the teachers of the Church Day School to bring children into the Library each week to hear a story and to learn to enjoy books. Under the capable leadership of Mrs" Corey this project is still being carried on with great success. The young people of high school age have been encouraged to take the special Bible Credit Courses whích have been offered in our Church since L932" The Library has worked with all teachers to place on the shelves books requested for the recent Covenant Life Curriculum. They add constantly books that will broaden horizons, books that will raise ideals and open the eyes of our young people to the needs of our world for Christian Service. youth groups have met in the Library for programs and book reviews books have been taken to the various departments when requested" and A special section in the Líbrary has been reserved for parents" These books deal with the problems of family 1ife, the education of children, the adjustments of teen-age youth, and the ímportance of religious convictions as a lasting foundation for the building of christian homes, A most important service to the educational program of our Church includes resource material made available to teachers and an outstanding Reference Section" Bibliographies are compiled to assist those appointed each year to teach the Bible for the Women-of-the-Church. The December program for the Women including l-ists of recommended books for Christmas gifts has been artanged several times by the Library. The Library Committee has also sponsored book reviews for the Spring series of the Wednesday Evening meetings. A special" exhibit was one of 68 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 117 rare Bibles and Manuscripts brought from Austin college, in connection with a pageant on "The Unchangeà Word," written by Lou.i'se McComb on the history of the English Bible and produced on the loth Anniversary or' the date the Revised Standard Version first aPPeared" The Memorial Book Fund was begun in 1953 as a means of pernanently honorrecofd the ìng loved ones through gifts of boots to the Libtary. Book plates These giits, and notes are sent to both donors and families so honored. cared acfor knowledgements, begun by Mrs" Bertrand, have been most efficiently this fund to during twelve years by Mrs" Harland Mayes" The names of donors along with are permanently recorded in volumes kept in the Library, This work, generously has bookbinding, has been the contribution of Miss Mariana Roach, who shared her artistic talents since the Library was established" A word of aPpreciation goes to: The five women who have served as chairmen of the Library commit'tee:: 1953-58 Mrs. HenrY Inge 1959-60 Mrs. Janes Trent L96L-62 Mrs. Tom LoseY Mrs" Gaston Ha1lam L963'-65 Mrs. Harland MaYes 1966and unselfì.shly of her tíme and talents and has made a generously given Each has special contribution to the growth of the LLbnty" Mrs. Carlton Reed, for her continued diligence in keepÍng the record of people and events in chionological order in "The Scrap-'Books"" Mrs" Henry Bennett for her excellent book reviews and her constant effort, through publicity, to make our church family aware of the Library' Mrs. Hobart Price and Mrs. chas" Eversole for an improved filing system and more complete subject cards" Our ministers fãr words of encouragement, approval and of caution" Mrs" L, M" Evans, who since 1959 has given valuable assistance by adding the needed professional touch to processing the books" All the volunteers who have given countless hours, ideas, and eirthusiasm to the Church Library. In thirteen years the Library has gro!{n in volumes--from 500 to over 5,000; in volunteers--from three to a committee of nine members assisted by a staff of 20; in circulation--from 50 books to an average of 500 books a month" As the church grows the Library will face new opportunities and new to offer books that interpret Christian experiences challenges as it "onlinuu" books that will add new perspective to the Christian for the world of today, loyalty to the Christian faith' inspire will life and books that By action of the session on octobet 25, L967, the Library will bear the name of Ntadeline Roach Meyercord. Christian Family Life Committee The Christian Family Relations Council was st'arted in the L95L-52 church year under the l-eadership of Miss Louise McComb with Mrs" Ray Matson as the first chairman. It was a sub-committee of the Chri,stian Education Cornmittee. In LgS4 Dr" Edward Mohns joined the committee as its ministerial advisor. During the l-959-60 year the titl-e Christian Family Life Committee replaced bhe original title. 69 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 118 fts motive was to increase and deepen family worship in the home and at of nurturing spiritual l-ife in the church, and to institute ways and means participating programs were planned to and i'aníty. Laboratory, instructive, the farnily unit" Each year special family worship services were held "nri"ir tne sanctuary. There were churchground picnic suppers and weekend. farnily in campì-ng trips enjoyed at various church canp sites near DalLas. pamphlets on family worship were distributed and for a number of years brief faníly worship booklets were mailed to the church families before Easter or Christmas to stimulate family worship during these meaningful seasons. Some of these devotional booklets were written by members of the congregatíon especi.aLLy for the family unit for the particular season invol-ved" The booklet ior the Easter season in 1955 was written by Mrs. Paul Speaker when Mrs" Cecil Largwas the committee chairman. The Westminster Class sponsored a series of programs on Christian Family Nurture which were given by Dr. Gladys Guy Brown. The series met with great success and many requests were made for more studies of this nature" The Christian Family Relations Council, under Mrs. Paul Speaker's chairmanship, sponsored in the fa1l of 1956 several series of interactional groups in Christian relationships, These groups were lead by Dr. Brown and tied in with the successful series started by the Westminster Class" The studies were planned for a session of two hours one day a week and in series of four, sixu or eight weeks depending on the area of Christian life for each individual group, and the groups were usually limited to twenty-five members for each series" Some groups were planned for couples and they met at night or on Sunday afternoon" These laboratories in peÍsona1 Christian relationships were planned to help the individual mature as a Christian, to try to meet the needs of the individual to be more effective and comfortable in his relationship with God, with himself, in the family circle, and with his associates" Some of the interactional groups were especially concerned with the rearing of children so that they might grow in grace to be happy useful children of God" The interactional group program continued under Dr. Brown's skillful leadership until the farl of 1965 when the Christían Farnily Life Committee was combined with other committees in the Christian Education Department" The Celtic Cross Fellowship The Celtic Cross Fellowship is not an organization in the usual sense of that word: there are no officers; no dues are paid; there are no regular meetings. All members of Flighland Park Presbyterian Church who are committed to full-time Church vocations, or those who are seriously considering whether they are called to such a vocation, are eligible to belong to this Fellowship" The Life Enlistment Committee of the Session, with one of the ministers as advisor, has oversight of this group. Whenever there is a propitious occasion or a suitabLe time for the group as a whole, a meeting is arranged, usually a dinner meeting. 30, L952 was the date of the official organization of the Celtic Cross Fellowship, at a dinner meeting sponsored by the Life Enlistment Committee of the Session, Mr. Chester Cole, Chairman, with Dr" Elliott presiding and Dr" Boand assisting" The roster at that time íncluded Charles Angell, Ben Batenan, Rosemary Beachy, Reverend Dayton Castlernan, lìlarren Delafield, Carol E1lio'tt ' Joe Elliott, Dr. Hugh English, Phil Fanning, Geneva Giese, Josephine Gtegg, Ross Kirven, Charles (Bud) Jenkins, Una Mae Mangrum, John Pace, Billy Mack Reid' December 70 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 119 Moneta Speaker, Sue Tuggey, Bob ltlatkin, Douglas Simpson, Reverend Gerald Slusser, Betty Winsett, Janis Winsett , anð' Norman Wolf" ThepurposeofthisgroupistogivefelloyshintothosewhosharetheSense offer enwithin th" Ct'tttth and to feel that of call to a career in some form ãf-,riãL"try and work life to their -Ñåttt" t""*"t who fellowship couragement to those who ar" "".t|-ttg this in participate uff those it may be in the Church calling. this through found others have continue in such a church vocation,-ùut many association the assurance they need' are of three groups: Alumni Members The celtic cross Fel-lowship consists Presbyof care under those *to ure those who are in service; Active Members are people in teryoringraduatetraining;an¿R""ociateMemberSarethosewhoareseriously some of the grandest young proud" rn considering their call-. tnã fist includes justly is park Presbyterian church the world, a group of whorn Highlánd foll-owing members: December 1966 the Fellowship had the ALTMNI MEMBERS Rev. Rev" Rev. Rev. (at work in the field)-- and Mrs. Chas. Angell Ben Bateman, Pastor Kenneth W. Book, Pastor Dayton Castleman, Pastor Mrs. Paul oona ldson (¡¡a rY Moo re ) Rev " and Mrs. Ronald R. Garton Miss Geneva Giese Rev. Dan T. Hughs, Pastor Rev. and Mrs. I¡Ìi11 C. Jones Mrs, Felix W. KeYs Rev. Ross B. Kirven, Pastor Miss Una May Mangrum ACTIVE Mr. Mr. MEMBER^S Mrs. Newton Todd r Rev. Robt" N. Watkin' Jt', Pa Pasto Rev, and Mrs. Andrew Short' sto r Mr" Duane E" Mclean Mr" and Mrs, Fred S. Morrison Homer ASSæIATE MEMBERS (consideri.:ng Miss CarolYn Atlee Miss Mol-lY Badget Mr. John Kent BoYnton Mr. Pat CooPer Miss MYra Ha11 Miss Carol Hawkins Mr. Chas. (Bud) Jenkins Miss Jan KiPP 7L Ruggles) l,{rs. Paul H. SPeaker Rev " G. H. Slusser Miss Betty Jo TaYlor (in graduate training or under care of Presbytery)-- Ned H. Benson Don CaPlinger Mr" A. John Rev. and Mrs. John M' McCoY' Jr' Rev" Quentin,PaYne, Pastor or. an¿ Mrs. C" E' (Jack) Prince Mrs" Chas" H. Sanders Rev" JirnmY Dan Sanders, Pastor Peck) ttrs. nobt, E" Sanders (Bel1e (Dorothy C1a re Smith A, trlrs. Witf iam a Church vocation)-rd, Miss Jan Lasater (lnlrs. Chas" H¿ Polla Mr. Michael E. Love Mr" Paul McKenneY Miss Barbara Porth Mr" Eugene W" Putnan Mr" John E" SeaY Miss Frances St. Peter Miss Janet TaYlor Jr') Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 120 IF CHAPTER IX S0vIXTHIIG FOR EVERYONE AT HPPC titLe of this chapter is not just a wishful slogan, but a true picture in which cif this church. In the preceding pages, several of the activities in which the church The serve the church were described; now, the many ways membefs are being emphasized. Of course' the benefits are nearly the serves reciprocal; so both the people directly concerned and the church as a members í "ir"v" grow and develoP. whole j at Highland Park. And if groups or paint or of individuals decide they would like to learn to speakdoSpanish been arranged has so learn a certain craft or whatever--the opportunity to before, and it can haPPen again. Beginning with the youngsters and ending with the oldsters, the church is has special plans for various ages and sexes. For the littlest ones, there rn between Club" Fifty-Plus the Dày School and for the senior citizens, the is a wide assortment of activities with fluctuations from time to time as interests change. There really is SOi4ËIHING FOR XVERYONE þ¿ I i School History The Highland park Presbyterian ChurÇh took its place wÈth other leading churches in the establishment of a l¡teek-Day school in september L952' The Day School consisted of one First Grade and one Kindergarten group for fiveyeär-o1d children. The school continued successfully and enthusiastic-a11y and ihe Session of the Church made the lrleek-Day School a permanent part of the christian Education progran in 1954. At the same time they approved the addition of two more groups, one of Kindergarten and one of First Grade' Mrs. Harold E. Pharr was the Director of the school and worked with the Supervisory Board in establishing the highest stanoards possible, both educaonly tiànally and spiritually. From the beginning the school has employed Christian a with experienced and trained teachers who were professionally background and deep convictions. Dr, R. V. A11en, Professor of Elementary Teacher Education at southern Methodist university, was employed as consultant to Mrs. pharr. Student, teachers from the Education Department at SMU assisted the regular facultY members. The school term was set up to para1le1 the Park cities Schools and to observe the same holidays insofaf as possible. School hours were from 9 to 12, Monday through Friday" Facts which influenced the formation of this school were: an increasing awareness by leaders of the importance of training young children in Christian principles in their formative years; the strong,desire of parents that relígious instruction be given their children; the lack of provision for kindergarten and overcrowding in many public schools; and the desire of Church officers to increase services to members through wider use of church facilities. 72 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 121 training The curriculum for the Kindergar.ten included standard Kindergarten plus daily as set forth by the Association of Ctr¡-t¿troo¿ Education International Christian training and interpretation of all experiences" taught in public The First Grade curriculum included all academic subjects the specific school first grades with particular attention given to following Schools' Again the Courses of Study as outlined for children in the Park Cities first grade curriculum included daily Christian training' were made availThe Church School materials for Kindergarten and First Grade be an integral part of able to the Week-Day School so tnal the Day lchool mightwas that the Day the whole Christian training ptogr.t of the Church. It the felt school public best School provided an opportunity to advance a step beyond activities suited kindergarten and first grade. While both offer environment and on cooperative to the needs of children, the Day School based its curriculum behavior as a group life with many opportunitieS to live "the Christian way" of part of daily living. everyday life The great advantage in making the church a part of the child's interpreted who with a program providing religious experiences, with teachers was recognized by the activities in terms of spiritual gtoo,lit and development Park Presbyterian Church" first Advisory Board and the Miniãters of Highlandwith adults who are growing' Children'learn a great deal through relationãhips in a child seeking Christians. Tolerance, gãodness, love and reverence develop School the week-Day when he senses these qualities in ttrose around him. rn the child grows into spiritual awareness rather than being "pushed" into it' Day School' In 1955 another "newil feature became a successful partonofa the I'two-threerr plan' The Junior Kindergarten for four-year-olds was establ-ished fours older the and The younger four-year-olds attending school two days a week attending three daYs a week. in Senior The enthusiasm of parents kept a long waiting list and classes the comlrlith permitted' Kindergarten were added insofar as physical facifities Kindergarten in Junior class pletion of the new educational facitities, one more moved to Caliwas added and one more in Senior Kindergarten. When Mrs. Pharr Director' place as fornia in 1958, Mrs. Chas. Denman took her to a very real In 19ó5 and 1966 the church answered a call to minister the Day school tized autho Session need in the a¡ea of special Education and the These handicaps. learning special to establish a class lo help children with Opporfor high too capacíties aL ment children are described as children with to succeed academitunity classes as provided in the Public School, y.t unable who may be children are They problem. caLLy because of sóme special learning special Educaable to succeed in a small- group with expert guidance. Trained in the parents tion teachers were hired to teach these children. Grateful to help made has community are extremely apBreciative of the effort the Church our in this way. A maximum of eight children in a class is recommended' classes have averaged between six and eight. children The enrol-lment of the Day School has grown until L967 finds 240 two groups, in three Junior Kindergarten classes, seven senior Kindergarten First Grades, and two Special Classes' area of meetOne of the unique features of the Week-Day School is in the Clinical Psychologist' ing the needs of the individual child. Dr. GLadys Brown, worked very closeLy became Consultant to the Day SchooL staff in 1958 and has needs' their with the staff to unde'rstand children's behavior and determine 73 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 122 This has been an "in-service" training in which much progress has been made. Dr. Brown works with parents of Day SchooL children and has two series of intensive study with them, one in the fal1 and one in the spring" The testing program of the Day School is under the supervision of Dr" B¡own" This includes neuro.logical tests, reading readiness tests, and other tests to help evaluate the needs of children. All the children in the First Grade are given individual diagnostic tests as a means of better understanding each child in orderho help him function comfortabJ-y and happily" Children in the Senior Kindergarten are given Metropolítan Readiness tests and Banham Maturity tests to help determine their readiness for First Grade" If i.t seems more advisable to wait one year for First Grade, the recommendatíon ís made that the child be placed in a transition room between First Grade and Senior Kindergarten rvhere the chil-d's needs are met" Boy Scouts first chartered March 1945 with sixteen boys, Scoutmaster A" M. Assistant Scoutmasters Dee Downs and S" ltl" Szabo, D" W" McCord Troop I¡rliesner, Chairman, In L946 Dee Downs was Scoutmaster, W" R" Saunders and D. W. Committee The first Eagle Scouts were produced that year, lliles assistants. McCord, Morris. Jack Julian and Troop 80 was Sam In L947 C. E. ùlclntire served as Scoutmaster with WilLiam R.'Saunders and T. Alton as assistant scoutmasters. Four Eagles were awarded that year. In 1948, L949, 1950 and 1951, Sam T, Alton served as Scoutmaster with Brookin N" $Iadley' Jr. and W. R. Saunders as assistant scoutmasters. By August L949, when Troop 80 had 50 boys registered, the need for a separate organization for boys over fourteen years of age was apparent, so E:<plorer Post 80 was formed with Brookin N. Wadley, Jr" as A.dvisor, A1 Benjamin, Committee Chairman and D. l¡[. McCord and W. R. Saunders serving on the committee" The Post was formed with eighteen boys, all but one from Troop 80. From the inception of the Troop until 1950, D. W" McCord served as Troop Committee Chairman. John Janak, Jr. assumed this job in L950 and D. W" McCo¡d became Institutional Representati\Åe for a peiiod of five yearso Up untíl 1950 an assistant pastor had held the position of Institutional Representative. In L952 and L953, O. S. Judd served as Scoutmaster. In 1954 W" R" Saunders served as Scoutmaster, having been assistant Scoutmaster since 1946 and being the backbone of all troop camping these years, In 1956 and 1957, ltl" R. Saunders served as Institutional Representative. Scoutmaster in 1956 was F" I/t¡, Mayes, Ln t957, Nat Baker, In 1958, J. Douglas McDonald served as Scoutmaster, 1959 and 19ó0, Dan T, Hughs. In 1959 Brookin N. Wadley, Jr. served as Institutional Representative, Al Benjamin succeeded him and served as Institutional Representative until L964. In L962 John G. Russell was Scoutmaster, his assistant was Bill- Saunders, an Eagle from the troop, son of W. R. Saunders, who was stil1 serving on the committee. In Marih 1964, Troop B0 had reached such size as to warrant the development of another Troop" Troop 82 was chartered with 35 boys, Frank W. Campbell as Scoutmaster, Phillip E. Coldwell, Troop Comrnittee Chairman and J" Colbert Peurifoy serving as Institutional Representative for both Troops, Troop 80 reregistered at the same time with 37 boys' 74 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 123 Ln 2L years of scouting. Troop 80 has done producing an average of over one Eagle Sc it has 1ed well up the ladder of Scouting leaders have had their share of recogniti Saunders and Brookin N. Wadley, Jr., a1l award to well in its Scouting program' Scouters. the most to But, if tribute were to be paid to one man who gave of himself be to wo Ro Saunders, bring the great outdoors as a gtowing gift to boys, it wouldyearso Mrs" Saunders, Troop for eighteen who really made Troop 80 a great "u.iiãgof Troop 80" hís widow, recalls some early exploits Shortly after the formation of Troop 80, when a group of doctors generously was offered some prqperty out Preston Road to be used as a campsite' a contest acreage" appreciated held to decide on a name for thís rugged but thoroughly (Boy Scouts of The winner was Miles Julian and the name chosen was Camp BSOATE America Troop xighty). boy the patrols gathered around the campfire, one hungry boy one time, Another explodedJ can stuck his can of beans in the firã. The used had he discovered was it eat, made apple pie but when they got teady to boy found a soap powder instead of flour. On a trip to the Brazos River, one wanted to be patrol one camporee, Rock rattlesnake in his bedro11. On a White close to the road. When Scoutmaster Saunders went to check on the boys he found their tent had been stolen without even waking them' One night when Mr. J. Colbert Peurifoy continues as Institutional Representative for both is troops; Mr. Nat Baker is acting Scoutmaster of Troop B0; Mr. Frar¡k Campbell Scoutmaster af Troop 82, CamP Fire Girls and Girl Scouts at in 1953 that a committee was formed to organize Camp FireE.Girls M' Mrs" Highland Park church. This committee, Mrso wmo M. Elliott, Jr., Roeder, Mrs. Al Benjamin and Mrs. Robert Moody, started with four groups, each of which had two adult leaders. It had been the intention to have Girl Scouts also but there was no one to take the lead at that time. rt was has Fire Girls received enthusiastic support and the organízat'ion gfoups, Fire grown amazíngLy through the years. There are now seventeen Camp girls ãome meeting-at the church and some at various homes, Some two hundred are involved. are In the fal1 of 196ó the Girl Scouts came to Highland ParF and there both by observed presently two groups of ScoutS, Three annual occasions are the birthday Sunday in March when !"o,.rp": the Oãa-Oãughter banguet in Febnrary, body and the Play-Day at Camp lhu girf" and their leaders attend church in a The Camp Argyle in September after school has started. Both these organizations are under the guidance and sponsorship of a committee of the Session, with Mr. J' Colbert Peurifoy as Chairman' The Chairman of the Highland Park Presbyterian Church Camp Fire and Girl Scout Committee' Mrs" Robert B, Moody, is a member of this Session Committee. The other women on A" P" the camp Fire and Girl Scout Committee are: Mrs. George Dolph, Mrs,III, and Muse c. J, Mrs. E. Record, Mrs. W. Mclvlullin, Kimbrough, Mrs. Tom J. Mrs. Shane B. MurPhY" 75 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 124 Bible Credit Course The plan for accrediting Bible study in the Da1las High Schools is an outgrowth of a movement begun in Da11as in L925" The first Bible StudY Course was published in L928' The first Bibl-e Credit Course was taught in our church in l-932 and covered boLh the OLd and the New Testaments" The teacher was Mrs" Charles F. Anderson" The Course uras available to Sophomores and Juniors;in Sen;ior High School credit toward graduation. The Course required a minimum of forty one-ha1f for periods of ninety minutes each. The examina'tion was given in May under class of the Dallas Board of Education, In 1940 the Course was divided auspiöes the courses, one in Old Testament and one in the New Testament, separate two into years. Since 1960, classes in both Old and New Testament in alternate offered have been offered each Yeat. Ministers and teachers have encouraged the young peopl-e of our church to of this study believing that it would give a new appreciation of advantage take Cod's Word and that it would enrich their lives from both a as Bible the personal view. The Bible Credit Course is presently conduct'ed a and cultural by Mrs" Lee R" Slaughter, who teaches OLd Testament, and Mrs" David Powell, teaching New Testament" 1 The Vocational Guidance I P rog ram i What lrlill you Do With Your Life? Eleventh and twelfth graders involved in yoffi-nrofram InTiffinffi'rffiesbyterian Church are motivated to give the serious consideration to this question as "Futures Unlimited," the Vocational Guidance Program, is outlined to them in Septenber each year" I In L94g, the General Assembly of the Presbyterian Church, U" S. provided for the development of a plan of guidance which would help each young person in our Church make of his career a Christian calling, and which would supply hírn with the technical assistance needed for choosing his life work wisely ín our complex industrial society" Responsibility for the development of a program of this type was placed in the hands of the Board of Chrístian Education' ¡ t I { rf i In 1952 the Department of Christian Vocation, a part of the Division of Higher Education, presented to the Church what it felt to be a practical plan of vocation and educational guidance within the framework of the doctrine of Christian vocation" This plan was subsequently adopted, and the Presbyterian Guidance program came into being. ,1, i I In 1958 the Christian Educa'tion Committee, with Austin Watson as Chairman and Dr. Edward A. Mohns as Minister Advisor, began to relate the Vocational Guidance program to the needs of the youth of the church. Mr" Ray Montgomery was asked to serve as chairman of the committee to initiate the program" Other members who served with him were Pelham irlorris, Douglas Conner, Dr" Fred Fink, Charles Pistor and James Brooks. Miss BelLe Peck, youth director, worked as staff person to coordinate the committee's work. Charles Kirkham and Mrs" liladeline Meyercord, members of the Drama Committee, were asked to help publ Lcize the program through plays or skits. l4r" Kirkham wrote "The Biggest Bargain" and "Dial O for Opportunity" and these plays were presented by the young people to familiaríze the congregation with the program' following the Wednesday evening dinner in Currie Ha11. 76 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 125 and ¿ indicated an interest in the program t'aidestt Quite a number of young peopleenlisted or counsel0rs as serve to number of adults in the church were through the Vocational interviews, of series in a counselees to guide the Kit; this included a Guidance Guidance material then known as the Vocational A compreheninformation' pertinent nurnber of booklets on vocations and of ,er The objec1959" Apri1, in plutlshed sive ,,Handbook for vocational Aides" "u" tives of the program as outlined by the committee were: their place L. To bring informative material to Senior Highs concerning can express his faith in the future communities and to discover how a Christian through honest vocation. Highs for use in research 2" To Pro vide a Vocational Library for Senior is avail-able in book and pamphand reference. General and technical iniormation 1et form. the church who have volunteered 3. To provide counsel by adult members ofexperience' their time to a1low seniors to profit by their 4"Tocoordinatewithotherchurchprografnsin.providingvocationalatten. tion in related subjects" in which senior 5. To arrange for aptitude tests to determine theinarea areas' all Highs excel and to better understand one's capabilities Ayearortwoaftertheprograrnbeganotherswelenamedtothecommittee: Goyer and Dr' Robert Miss Martha chawner, Miss Eliz;beih ruaclãy, Mrs. wesl-eyreports were presented to Walker" Pel Norris was named Chairman. ðomprehensive the progress of the prothe Christian Education Comrnittee by Mr. t'loriis stating gram with needs and recommendations for future work' for Youth"' Tn L962 a new manual, "You and Your Lifework--A Christian Choice Theological Seminary and wiitten by Dr. Albert winn of Louisville Presbyterian is in three published by Science Research Associates, became available' This sections-Leader's Guide, Student's Guide and Parents' Guide' 1963 Mrs. Edward Roeder, staff named secretary to the committee to work In program. Since that time approximately year have been involved in the program to the Presbyterian Guidance Center at at the end of the year further counseling. Evaluation dinners were scheduled resource with both aides "rrd "oun"elees evaluating the program" Extensive a biblioreceiving material was set up in the Church Library with all involved graphy. J" McDaniel was named Christian Education minister under and assumed his duties in July Lg64 al which time the program continued committee' the of his supervision with Mr. Norris sti1l serving as chairman with Arthur Xfforts were made to coordinate the cornrnittee's work closely Flinders, superintendent of the Senior Hígh Fellowship' EducaIn the fal-l of 1964 Mrs. Byron Kennedy, who came to the christian program" the for tion Staff as Youth Director, assumed staff responsibility Putnam Dr. Dean Klpp served as chairman of the committee in 1965-66 and Eugene Mr" and Department' High was named to the committee representing the Senior coordinators with The Reverend Faries Mrs" Jarnes G. Mi11er, Senior High Supeiintendents, worked as the committee. 77 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 126 ll program For the year L966-ó7, The Reverend John McCoy is in charge of the and chairman youth, Ritchie as committee working with Mrs. Robert to ^" MinisterHolland paryoung people currently are as secretary. Twenty-six í,rr.-nãffy t|ciPatíng in the Program' AthLetic Program Highland Park had a For several years in the late 1930's and early 40's, of young men" Usually' team good--softba11 very a years , u.ry u.iiue--and, in some week during and usuallv' but Park, caruth at summer the twice a ä;å"";;r" played such as Highland ?ark Methodist' university not always, agarnst other church teams etc' Christian, pãif. no"tf"dist, Northway games' Members of this In the summer of L942, ÍIPPC won 25 and lost only two , Cecil Ewing, Jr., Jack Grongerg, Rush d Mill-er, Bill Oneal, Dell Ramey, George ers in different years included Henry ic" Eversole, Ctifton Wilhite" InLg4L,ChicEversolebrokehisarmthrowingtheball;f¡:omtheoutfie].dtt¡ it even more odd, ib was the homeplate--quite an unusual accident--but to make arÜist and Harold Brand last play of the last game. Dell Ramey was the fast-bal1 pasbore :is now Pres:ident slow-ba11ed the opponents. Donald Mi11er, then assistant for the of pittsburg Theological Seminary, while ðtiftott Wilhite n<¡w sets styles ladies " to field In the early 193O',s, it may be recalled HPPC one year attempted in lacked team a basketball team made up of young married members' what this skill was made up by their enthusiasm,l toward boys of In recent years, the athletic program has been directed bear witness to Juníor and senio. Higt school age; a large number of trophies played some years the success of their efforts. Both basketball and baseball are Each team has with the choice depending on the number of players interested' of members are players been coached by a voluntãer member of the church and all the church or a Sunday School class" Drama at Highland Park Presbyterian Church Literal In the Medieval Ages drama had a rebirth in the christian church' e liberaL use of allegory characterized ent by drama left the Church, but in at through the use of drama the Christian rm which may speak to some persons as ght" During the forty years of cltama pageants and at Highland park presbyterian church there have been many plays' steps of the on the sanctvaty2 in the used dramatic interLudes. Drama has been Hall' in Currie and classroom in bhe Church, on the lawn, on the side street, playplays, plays, one-acÙ three-act formal Drama has been used in the sense of 1ets, scenes, dramatic presentations, readings and as accompaninent to mrrsiCal programs o early The recent history of drama in the church at Highland Park began in was committee Education christian the under 1958 when a new separate committee consisted of appointed. This càmmittee was known as the Drama subcommibtee andCaplinger' Mrs. Cliff A. Jones, Chairman, and commi'btee members, Mrs" ÌIaroki tó Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 127 Dr, Frederick Fink, Jerry Jordan, Mrs' Kenneth Meyercord' Bill Proctor and Mrs" Fred Underwood. in hhe church was under the direction of th:is cornmi.ttee a new organizatíon words Thespians joining the of formed called the Thesbyterians which simply was a declared the and Presbyterians" The initial constitution for the Thesbyterians a medium as for pufpose of this group was to study and promole.the dramatic art Christian rethe interpreting and expressing the måra1 and spirituat truth ofpurposes: (a) to .bhis two.specific have group shall the ligion. To achieve its seras insofar assume responsibility for dramatii production in the Church Park Highland of vices are needed and requested by the various organízations significance' presbyterian Church and (Ul to produce dramas of religious assisted president of the organizatíon Ìvas lloward Dunham" He was liliss Garrett" O' by Pelham Norris and Mrs, Mable Vaníandingham and Mrs' J" in drama' provided Louise McComb of the Church staff, who haã intense interest interested in drama in liaison with the Church staff. Miss McComb was vitallygetting the group going" aLL of its various.forms and served as a catalyst in provided basic Ïn April, 1958, a Drama Workshop was held. This workshop It presentation' play in training in speech, stage craft and tlchniques involved such as plays from scenes A number of was well attended over a six-week period. ttClaudia" were presented together with a and Earnest" Being of "The Impo¡tance and Mrs' play entitled, ,'The SpeãÍa1 Visitorrrwhi.ch was a script prepared by Mr' prethis oF success Ut". Cliff Jones. After the ;initial Howard Dunham, Jr" "nã sentation the Thesbyterians undertook th Not" and "The Dark places",' The first p was interested in theatre. This was Joh first youth minister at Highland Park Pr an opportunity was given to any member o asked to join in the fall of 1958 bhe Drama Comnittee and the ThesbYterians wereEve serÚïce' chiristnas with the Family Life committee in presenting the Family in format varying program From'1958 ùnti1 tg66'this practice continued with the and style from Year to Year" The first Member canvas'r In 1g5g and 1g60 the Drama committee joined with the Every form' In unique in a congregation Committee to present the church budget to the played by B:ill Proctor, 1g5g Dr" Elliott as the space gravei,er took Mr" Skeptic, in foreign lands with money of churct on a trip around the world showing the use a final examination of the use of church was set up on the church lawn by which su were shot into space. The following yea was presented in the sanctuary. This pr be done only with human hands, but that to put them to work. of The Drama Committee and the Thesbyterians assisted other otganizations play was a the church in presenting programs of.varied types. As an example, the Church through presented in connection with the vocational guidance offered by play this program of a a program called, "Futures unlimited"rr Through the medium ,"u" lñt"oduced to the teenage chiLd in the Church School" t'The Case of A number of plays have been held at Easter time such as an abtempt Htrmanity vs" Pontíus Pilate" where eye witnesses gave testimony in responsibility guilty o,f to resol-ve the questJ.on of whether or not Pilate was for Jesus' death as a criminal on a roughhewn cross outside of Jerusalem" 79 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 128 Christmas ptays have been held for a number of years" .tn 1958 the play, ,r1¡s Bishop's Candlesticksrr was presented. Later the play ''Why the Ch:imes R'ang'* was Presented' I' pageants were presented" Louise McComb wrote a historical pageant drarnar*The Unchanged Word"''' It t:izLng the history of the Bible in English, entitled different years. In 1960 t:he D:carna Commibcee *ã, CL""" on the church lawn in two presenting a program called '*The Div:ine in department music the :ol"ã¿ with choírs and a speaking choir" The of various music which utíLized ðommission" For example programs for other organizations. presented 1964 in inesbyterians ,Jerry Mr" and Mrs" and Mr. and Jordan Dunham, Howard lrtr. of Á'ca"t consisting grs. :onn McCoy under the direction of Mardi Jones presented a play "for the ,nn,r"l spring institute of the Dallas chapter for the National Conference of Christians and Jews. Programs were held in connectíon with the Church school upon request and members of the Drama Committee have gone into the classrooms .nd girrun demonstrations to the Church school teachers as to how they may utilize drama in the Church school. I li t: li :ì ri ;i 'ii t., ii to time other activities of the Thesbyterians have taken pLace of plays including such plays as "Gideon," "After the Fall," reading the such as rtBilly Buddrtt ttJonah,tt ttOgr Townrtt ttLutherrtt t'JoB",tt "Firebugs,rr etc" A class in religious drama "Xnds and Means" was held. One of the outstanding presenta,tions iñ tne history of the Church was the production of "Family Portrait" in the sanctuary in 1966" This large production utiliaed a cast of twenty-seven From time and numerous backstage PeoPle. During the years the Thesbyterians and the Drama Committee have effectively presented through d¡ama the special seasons of the Christian Church--Christmas, Èaster, Reformaiion Sunday and others of special interest. They have promoted the use of the drama in individual organizations of the Church as a means of vividly demonstrating the message to be conveyed. They have presented through drana, major emphas{à in the life of our Church such as the brrclget, s'tewardship, vocationalguidance,worshipandothers"Theyhaveencouragedtheuseo.fin'formal drama as a teaching method and they have developed in individual nembeÍs of the Church an esprit de iorp and an enjoyment of the techniques needed to give formal and informal presentationsn Through the use of drama the participants have enriched their own lives and hopefull-y the lives of obher members of the Church. A long range goal of the Drama Committee is to calry forward these purposes in ever-increasing strength until finally there ís a minister of drama in the same fashíon as there is a minister of music sìnce drama has a peculiarly unigue way of speaking to persons in our time about the meaning o;f life, the teachings of Christ, and the place of the Church in the modern world" Oontact By now most of the members of HPPC have learned about Cont'act, the monthly newsletter that keeps persons on duty with the armedTffies informed of events at the church and in the city. The late Theo. E, Jones, who was instrumental in originating this fine service, was kind enough to set down his recolLections of how it started: that we "When Dr" ELliott first came as our minister, he was surprised had no otganized effort to keep up with our service personnel, So he appointed a committee to try to do it. As I remember I was on the first committee, which is still- in existence, because we have had members in the service somewhere al-' rnost constantLy since that time. 80 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 129 ìfiE parents of men and women in lhe service \{ere asked to notify this committee of'where their relatives were and .i,n rvhaL parlìcular branch of the service" We had men in every service branch includlng lhe Merchant Marine, the Army, Navy and Nttrsing. the FBI, the Seabees, etc" Women also served,in -uvere rnembers of the church or The maximum reached a total of about 325 who active in the Church School" Their names were listed on a board in the church o'The lobb y " "To these we sent each monfh a rnimeographed bulletin giving general news, activities in our church and news of individuals, of where bhey were and what they were doing" A special ef,fort was made to get news of each one and include his or her name in this bulletin that was caLled Contact. "Of this large nurnbelthat participated we know of only six that were killed in action during the war or were listed as missing and presumed dead" One other was accidentally kilted in Okinawa a,fler the t:ighting stopped. One other was killed in training at home. t'Fi1es were kep t o,f Contact at the chur'c,h and are stilL avaiLable there." Chance.l Garden Club The Chancel Garden Club of HPPC was organized in Marclt, 1954, and has served not only as a source of good Chrisùian;fe.llowship among women in the church who love the growing and arrang;ing of ,flowers, but its members have served the church in placíng arrangements in the chapel anct parlor every Sunday, and decorating tables for dinner, luncheons, buffet co:ffces and teas" Mrs. R" E" Patterson, founder and teacher of'the club, holds a nationally accredited flower show judge's certificate. She obtained permission to organize the cLub from Mrs. Cooper WyatE, who was Presiioent of the Women of the Church at that time, and Mrs. Wyatt in turn conferred w.ith Dr, Will.iam M. Elliott, Jt", who gave his consent and encouragement with lhis statement: "ft is an appropriate study for our church women, since flowers are the very handiwork of God, and therefore, the most appropriate decoration for the church." The club has four officers and four appointed committees: Telephone, Flower Funds, Yearbook and Photography; it has six standing committees: Chapel Flowers, Church Parlor Flowers, Men-<lf-the-Church Dinner Decorations, Church Officer's Dinner Decorations, Women-of-the'-Church General Meeting Decorations and Growers'Committee. When a new member joins lhe club? she automatically becomes a member of one of the standing committees" If she chooses to be a Grower, she must have a garden, eithe¡ indoors or ouldoors and must make a good contribution of plant materiaL at least once a year. She receives a half hour Lesson in Horticulture once a month. The roembers receive a one-hour arrangement lesson once a month, and a11 bhose ¡dlr: are on flower arrangement committees are expected to go to t'he church and arrange flowers for an hour once a month" Sånce the church is large and the Chancel, GarCen Club smal"l---only 30 actrive members--the club does noi arrange,flowers fe'¡r t,he sancfuary" These Large anit i.mportant arrangements are made by f'lo¡jsls" Fifty*P1-us Club The SO-PLus CIub of 'bhe Híghland Park P:resbyt:erian Church came into being through the efforts of Miss Louise McComb, ReLigiorrs Educahion Dírector, and Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 130 8l I A group of the okler members met with f forming a club for the senior members aken care of in the church activities' club and Mr. enC Mrs" D, lt¡" McCord up " .I t rva s decided Lhat the fi rs t Decernber 10, 1954, from 10100 to 12:00 t I I : by bhe fnvitations were ma:iled to all prospective nembers of the club Visitor Parish H9we, Ralph by Mrs" provided were sponsofs; Names of such members the called it was and be social was t;o club for the church. The purpose of the good a it was that agreed club of the members Fifty-plus Club tempotutìry. All Fifty:Plus C1ub. Anyone needing transportation name and therefore it i" sti11 the or the church office" The Club was under was to call either Mrs. Howland ButtLer Education Department the direction of the Recreation committee of the christian of the church" ThefirstmeetingonDecemberl0,l'gs|,wasagteatsuccessanditwasdeon the last Friday of the month, cided.to continue the meetings once each month date and time has continued meeting The in currie Ha1l from 1o:oo to I2z0o a.m. games and fun but has singing, for meeting through the years, It has been kept a the meeting are sent to expanded into much more than that" Announcements of month' each r"tb"." and prospective members 9, 1956, the Club Shortly after the death of Mrs. Anne Jenkins, February our church, decided to continue the work of Mrs" Jenkins, a long-tirne member -of unusual countries and who had collected cancelled postage stamps of other of them and turned the some sold Jenkins Mrs. domestic United States stamps" the Bible in many 1anmoney over to the American Bible Society for printing stamps were sent to guages to cement the ties of Christian Brotherhood" Other children about other people the missionaries in distant lands for use in teaching and how if we knew and their customs, to illustrate how nearly we are all- alike eachotherbettertherewouldbelessstrifeintheworld. collectíon,'t wording Letters explaining the "Anne Jenkins Memorial stampmany foreign newsfor an advertisement, and a one dollar bill were sent to paper, in an effort papers, asking that they print the advertisemen't in their foreign from people to procure foreign stamps that rnight be exchanged with country' shortly lands who were interested in starnps from that particular countries, nínety letters after several advertisements had teen sent to foreignletters were written in and over 5r0OO stamps had been received. All of the contact' Some English and there "u" un amazLng desire expressed for outside pen pals and one wanted to exchange stamps, some wanted magazinesr Some wanted BibIe' American man wanted: ,,1. Bible in rnodern English speech. 2" Slang firm" business a in 3" Commentaries of the Bible"t' This man was a stenographer son in Medícal He was 45 years old, had eleven children with one 2l-year-old didn't have school. The club sent him an illustrated New Testament but it opportuniby for funds to send out many books. This, however, was a wonderfulby members of the missionary work. Also, many stamps were saved and collected Club and the church' which members The Fifty-Plus club decided to have a christmas card made card was The Society, Bible could se1l, all proceeds going to the American of l4r' and ltlrs' (granddaughter ì4ontgomery designed by Mrs" Mary Elizabeth DeVore a message of John W. George, chatíer members)" The froni of the card bore catd, reading the on greebing inside the Christmas to all the world and arouno ,'May God hasten the day when there shall be Peace on Earth and Good Will bo A'11 Liberty Men,,'six stamps were placed--the top stamp being our u" S. three-cent to sent was cards stamp with the inscripiion "In God We Trust"" One of these I : l 82 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 131 the various countries of the missionaries and some of bhe Scc''-tt Troops o:fwith rnessages wråtten sent cards, Pictures and letters to the Fir"ty-Plus club in their own language. Ihe Fifty-PLus Club was written up in Stamps Maga'zíne for their stamp a ct iviti es " As the Club grew, many other activities entered into the fun and fellowship' In November 1956 members of the Fifty-Plus club entertained the Men-of-the-church many' with,,ye O1-de Tyme Concert," the t"tb"t" being dressed in clothes from concert this staging and for preparing many years ago" The club had great fun line' last the y it to and the ¡rten-of-tne-Church appeared to enj' at Mo-Ranch for Some of the members attended Senior Citizens Conferences older people' the of enjoyment the the purpose of learning fnore ways to further get together At one of the meetings it was suggested that some of the men enough courts not were there since on one or two days a week to pLay shufileboar¿ came into Shufflersil thereafter "The to go around on Fifty-Plus day" Shortly necessary. was day another being and before long another group on many and many A request was received from Parkland tlo,spital. for cancer bandages do could thgt fett They bandages. the of the ladies spent the play tirne making without the play if they were helping somebody" State word came to the c.Lub concerning the needs o;f 'b?te patients at Terrell makbegan ladies our of group a Lena Jones Hospital" Under the guidance of Mrs. for made were do1ls ,,yo-yo,, many Many, dolLs for the hospital children" ing Terrell and for the Children's Hospital" The needs for Terrell- grew and for several years a group, of these ladies patients, have met at the church twice a month to make needed clothing for Terrell jackets, Christmas pajamas for the children, arm and knee pillows, lap robes, bed they this of all to In addition articles" needed gifts and many, many othår have solicited and gathered together all sorts of other things--clothing, furni'ture, radios, televisions, magazines, books, Plastic bags, etc.--and have found a way to send them to TerrelL Hospital for the use of the patients" their At present this group of ladies and many o'thers at the party spend sent then are cards The play time cutting tne 6acks from used Christmas cards" Mission. the at charge thei.r to the missionaries for use with the children in occasionally programs are varied by moving or still pictures, taLks by missionaries and others, hobby demonstrations, etc' Since the Club was growing and many members had no way to get to the parties a Transportation Committeã of younger women was fo¡med, headed by Mrs" Thos' W' from Finney" For many years these *o*"ã have called for and taken members homegames playi'ng in needed where gladly helped the parties" nuring the party they with the older folks and then assisted in serving the l-unch. Mrs" Joe E. Lawther was pressed into service as song leader and entertainment chairman for a period of singing at the beginnång of each party" Miss Ruby lfalden accepted the responsibility o,f membershíp chairman. al-so sends birthday, sick and sympathy cards to member's' Last year it was decided that we needed a ChapLain and Dr" L" McD. was chosen. He has been a faithful and welcome addition to the Club" 83 She Kennedy Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 132 After the meeting period a delicious lunch is served, Mrs" Edna Walker, with the assistance of her faithful helper and excell-ent cook, Mrs" I,irnma lla1lace, started the pattern for the delightful lunches. Thís pattern has been continued by:the hostesses who have followed her: Mrs" J. E" Lawther, Mrs" S. J. Pajeski and Mrs. R. J" Clontz. It was really a wonderful day for the senior members of our church when the Fifty-Plus Club came into being as it has added years of pleasure to many lives" The whole Club is grateful to the Ministers and Church Offícers for their help and encouragement which made this Club possible" Shuffle rs I I Organízed about ten years ago, the Shufflers is an organization composed men of the Church. They originall-y started meeting in Currie Hal1 on Thursday mornings at 8:30 a.m" to noon. However, the group grew until it was necessary to form another group which meets on Tuesdays" of retired Mr. George Holdridge, as active Elder in our church and one of our Church School treasurers, is the president of the Thursday group, whíle Mr. John Glendenning is the new president of the Tuesday Shufflers. Those who prefer play shuffleboard--others try their hand at dominoes. Sometimes the going gets pretty rough and a self,-appointed referee has to step in and solve a conflict" To make the atmosphere more charged with a competitive spirit, trophies are passed out on a regular basis to champion Shufflers and domino sharpshooters. Newcomers are welcomed by bqth Thursday and Tuesday morning groups" Each Shuffler contributes $1.00 each year to help pay for the trophíes and pocket change is collected from time to time to help with theÍr worthwhile benevolent progran. 845 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 133 @.s CHA?TER X WE DO OUR PART The Presbyterian Xxtension Committee of Da11as, Inc. The Presbyterian Extension Committee of Dal1as, Inc. was organízed in L947. It was primarily the brainchild of Rr'verohd Cecil H" Lang, D. D., who was then Executive Secretary of the Presbytery of Dallas which has since been renamed the ?resbytery of Northeast Texas, Dr. Lang discussed the project with Christian leaders of Presbyterian churches in the Dallas area and, particularly, of the Highland Park Church where he regularly attended services. tors The plan of organization which was evolved provided for a board of direcentirely of laymen with representation from every church in the city. composed L. R. Klein, a ruling elder at Highland Park, was elected to be the first President and a budget of $50,OOO was adopted with proportionate allocations to the various congregations in Da1las. At the time of the Extension Committee's organization not a single new Presbyterian Church, U" S., had been started in the Da1las area since Highland Park in L926 and Sunset about a year later, a period of twenty years. Both began as mission churches sponsored by First Presbyterian Church downtown. During this time the population of the city had nore than doubled. Casa Linda vûas the first church to be sponsored, followed soon by Wynnewood, John Knox and Preston Hollow. Also one of the early projects was the relocation of the Sunset Church in Oak Cliff. Since then about one new church each year has been organized, the usual procedure being for the Committee to donate a site together with a challenge gift of varying amounts ranging between $25,000 and $501000. The total of new churches now stands at eighteen and the area of operation has been extended to include the whole of Dallas County. In addition to the new churches started, two have been relocated. Officers of the Committee elected for L967 at the annual meeting held on Januaty L2 are:, President, Dales Y. Foster (First Church); Gerald Galbreath, Vice President (Northridge); George E. Wilkin, Jr,, Secretary (Highland Park); Arch West, Treasurer (Ridgeview). Past presidents in order of their chronological service are: (1) L. R. Klein, Highland Park; (2) W. N. Stewart, Sr., First Church; (3) A. E, Chester, Highland Park; (+) Ceorge R, Jordan, Sr., First Church; (5) Julius H. Smith, Oak Cliff ; (6) Dan C. lt¡illiams, Highland Park; (7) Robert M. Allman, First Church; (8) John Straiton, Preston Hollow; (9) Austin B. Watson, Highland Park; (10) G. R. Hollingsworth, First Church' (11) F" O. Detweiler, Preston Hollow; (12) A. D. Ha¡der, Highland Park; (13) James G. Blanchette, Jr., First Church; (14) Haywood C. Chalk, Casa Linda; (15) Raymond Campbell, Jr., First Church; (16) A, Morton Mosher, Wynnewood' (t7) Julian P. Barry, Highland Park; (l-8) A" E. Streitmatter, Northridge; (19) H" H. Mennefee, Preston Hollow. Of these Messrs. Stewart, Jordan, Straiton, and Mosher are now deceased. 85 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 134 llPresbyteri an Village The Presbyterian Village was completed and occupied on July 31, L962" Highland Park Presbyterian Church played a great part in the organLzation of the village and has always been ready and willing to participate in every way. Highland Park's quota from Presbytery was $t9e,OOO which was accepted and paid in ful1. Serving on the original committee were Dr" Wm. M. ELliott, Jr. and two ruling elders. At the present time we have three elders on the Board of Trustees" During the past four years we have had thirteen residents from Highland Park Presbyterian Church. We have Lost five by death anct one moved awayr so that now there are seven of our members as residents. Three of our Hi$hland ?ark women are serving on the Village Auxiliary Board at present (196ó-1967). The fellowship hall is named in memory of Mr" and Mrs" Leyland lttight. Mr" Wight was an elder in Highland Park Church. At his death he left a nice contribution to the Village. Many have contributed gifts, memorials and to the endownent fund. A woman member of year gave a station HPPC furnished five rooms in the infirmary, and, last wagon. The women have responded to work in Motor Corp, Bible Lessons, Programs, Health Wing, Social Activities, State Fair Volunteers for the Arts and Craft Booth, and in many other ways. The Presbyterian Hospital The first man to commit himself to the idea of a Presbyterian Hospital in Da11as was Dr. Frank H. Kidd, Jr. As a conscientious surgeon he knew the increasing need for more hospital beds in Dallas. As a conscientious churchman he wanted his church to provide that needed ministry of healing, As a medical doctor who had received his training in a "teachíng hospital," he wanted the Presbyterian Hospital of Dallas to be associated with The University of Texas Southwestern Medical School. Dr. Kiod shared his ideas with his pastor, Dr. William M" Xlliott, Jr", pastor of Highland Park Presbyterian Church, only to discover that Dr. Elliott had been thinking along these lines for a number of years. But what was the thinking of other Presbyterian doctors in the city? A document was circulated among the medical doctors in Dallas whon Dr. Kidd knew to be Presbyterian. l\Iith only one exceptíon, they affirmed the need of a rnajor hospital and agreeC that if such a hospital- were to be built, it should be located adjacent to the Medical School. Having received this kind of assurance, Dr. ElLíott committed himself to work for a Presbyterian hospital in Dallas. If a major hospital seemed to be needed, were the Presbyterians of Dallas wi}ling to commit themselves to such an undertaking? Dr. John F" Anderson, Jr., pastor of First Presbyterian Church, invited a group of prominent ?resbyterian churchmen to a luncheon at the Da1las Athletic Club. The men who attended that meeting were interested anct expressed the hope that further explorations would be made" Later, a luncheon meeting was held with a group of ministers which represented the three Presbyterian branches in Da11as. That group was unanimous in approving the idea of a Presbyterian hospital in Dallas, Was such a thing possibl e? 86 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 135 ùtr. Karl HobliizeIle, President of the Southwestern Medical Foundation, where they made inquiry about the possibility of the Presbyterians acquiring land adjacent to Parkland Hospilal and the new medical school building" Mr, Hoblitzelle gave some encouragement but expl.ained thab any such undertaking would have to be worked out with the Board of Regents of The University of texãs. He also explained that a site plan for the Southwestern Medical Center would have to be evolved before the Foundation could Dr. Kidd and Dr. El-liobt then went bo make any commitmenbs. Dr, Elliott introduced the idea of a Presbyterian hospital in Dallas to the Da11as Presbyterian Pastors Association, the on1-y orga n:Lzed group in Da11as which was representative of all branches of the denornination" A committee was appointed in 1955 to keep in touch with the movement and to keep the Presbyterian Pastors Association informed of its progress. with Dr. A" J. Gill, Dean of of Texas, pursuing the possibilities of Presbyterian Hospital being a teaching hospital. Thus, by the end of the year 1955? the idea of a presbyterian hospital had been åntrodused'to all the responsible people involved" The seed-thought had been planted" The question remained: Would it grow? Meanwhile Dr. Kiod was in communication Southwestern Medical School of The University For three years, lhe Presbyterian Hospital of Dallas was a stepchild" Every one concerned thought her to be winsome and desirable; butthere was litt1e serious thought of adoption. However, the enthusiasm and faith of Dr" Kidd did not wane; and as the tã.;ot hospitals were having their financial campaigns in the city, there were thoughts and conversations about "The ?resbyterian Hospital" among many of the solicitors and contributors" The idea was growing in the minds and hearts of the citizens of Dallas" In 1957, under the leadership of Dr. Kenneth L" l4auldin, pastor of St' Andrew's presbyterian Church, the Dallas Presbyterían Pastors Association appointed a steering committee with a membership of five Presbyterian medical doctors, five presbyterian ministers and five Presbyterian laymen. This committee was instructed to explore the need for a Presbyterian hospital and report its findings to the presbyterian pastors Association. The organízationaL meeting of that committee was on January 2, 1958, in the Parlor of the Highland Park Presbyterian Church" Those present for the meeting were: Dr. Frank H. Kidd, Jr", Rev" John F, Anderson, Jr", Rev" WiLliam M. El1iott, Jr., Mr. Josh Field, Rev. Jasper Manton, Rev. Kenneth L. Mauldin, Dr" Philip Newell, Rev. Klahr F" Raney II, Dr" Joe Roach, Mr" J" Milton Smibh and M¡, Toddie Lee Wynne, Jr" ' replesenting Mr" Wynne, Sr" Dr" Kidd was elected chairman and Rev" Mr. Manton was elected secretary. Other members of the committee at that time were Mr. Artie Barnebt and Dr" Ramsey Moore. By the time of the committee's March meeting, Mr. Fred O" Detweiler, Dr" F. Clark Douglas and Mr. Carlton R. Winn had been added to the committee. 15, 195'7, the committee met with 'the Hospital Administrators in Dallas" Guests attending the dinner were Mr" Boone major hospitals of the Powel1 (Baylor Hospital), Dr. Bolton Boone (Methodist Hospital), Mr. A1 Scheidt (Parkland Hospital) and Mr" Ed Maher (representing Sister Mary Helen of St' Paul Hospital). These men gave encouragement ano offered every possible assistance to the committee in its efforts to erect another church-affiliated hospital in Dallas" On November In 1958, the Steeríng Committee secured from the DaLtas County Campaign Screening Committee the date of May, Lg6L, as the date for the city-wide financial campaign for the Presbyterian Hospital" (Later the campaign date was postponed one year becaùse a site had not yet been obtained,) During that year, a Charter was secured from the State of Texas, explorations were made of various 8'7 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 136 possible hospital sites, and communications continued wi'üh Dean Gi11 rel-ative to lhe presUyterian Hospital being a teaching hospital in t'he program of Southwestern Medical School of The University of Texas. Under the Charter secured in 1958, the members of the Steering Committee appoÍnted by the Dallas Pastors Association became the Board of Directors of the ?resbyterian Hospital" (In the Amended Charter secured in 1959, the directíng board was named the BoarC of Trustees. I I lr 1i I ) t: ìl t.: The year 1958 was a year of study, organization, frustration and some progress. One of tne brighter moments of the year was the entrance of l.,lrs" I.4argaret Smith of Highland Park Presbyterian Church on the scene to take care of the clerical detaiLs of the Board. Mrs" Smith firmly believed in the possibility of a presbyterian hospital in Dallas. In addition to her personal contribution of time and service, she and her mother, Mrs. KatiebeLle D, SwaLlow, became the first benefactors of the hospital by contributing $100,000 as an endowment fund to be used to pay for medical care given to persons unable to pay for such care. I I I I I il ,t ,l I I I :.i it ¡,t !ll !;l I il ii ii During 1959, Dr. Kidd visited the meetings of the Presbyteries of the three branches of the denomination in the Dallas area. He informed them of the plans for a Presbyterian hospital in Dallas" Each of these church courts received Dr. Kidd's report with much interest and gave expressions of appreciation and encouragement. But there was no action in 1959 I I ìl it ,tl I Even at that time however, the seed-thoughts which had been planted for so many years were continuing to grow. Responsible people in the city of Dallas were beginning to warm toward the idea of a Presbyterian hospital in Dallas. Toward the end of the yeat, overtures of interest and encouragement were directed toward the Board of Trustees from nany sources in the fields of business, medicine, and community-interest. I I I { I { t I I I I Early in 1960, the Board was confronted with the prospect of a second ?resbyterian hospital in Da1las, a movement headed by a Dal1as lawyer" The Board of Trustees took steps to effect a closer working relationship with the three branches of the denomination in the Da1las area. Each of the Presbyteries was asked to assume the responsibility of naming one minister to serve a three-year term on the Board of Trustees so that there would be three ministers on the Board of Trustees at all times, one in each class as a representative of his respective presbytery" The Presbyteries were also asked to re-affirm their actions taken in 1958 in which they gave their blessings to the Board's efforts and to give their official approval for the Board to use the name "Presbyterian." All three of the Presbyteries complied with these requests and thereby accepted this working relationship with the Board of Trustees of The Presbyterian Hospital of DaLlas. (Tne charter of the second group was withdrawn" ) Then Dr. George W. Dana, Xxecutive Director of Southwestern Medical Foundation, met with a committee from the Board of Trustees of the Presbyterian Hospital of Dal-las on February 16 and informed the committee that the Foundation could not provide land for a Presbyterian hospital" Consequentl-y, the Board began to l-ook for a site north of Loop 12" The land being vacated by the Reynolds Presbyterian Children's Home showed enough promise for the Board to take an option on that property" The idea of a Presbyterian Hospital of Dallas did not really begin to take on form and srrbstance until Mr. Toddie Lee Wynne and Mr. Toddie Lee Wynne, Jr" advanced the necessary money to finance a projected plan of anploying a hospital administrator and setting up planning offices in Dal1as" This opened the door to giving Mr" Roderic Bell an invitation to become Hospibal Administrator of The presbyterian Hospital of Dal1as. Mr. Bel-l was especially qualified for the 88 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 137 job. He had long been recogni,zed as a most capable man in the field of hospitat a,lministration" He had served eight years as Assistant Adminístrator to Mr" A1 Scheidt at ?arkland Hospital. He was a dedicated churchman and an officer in Highland Park Presbyterian Church. Mr. Be11 accepted the invitation" ALready he had been captured by Lhe vision of'a P;resbyterian hospital in Dallas" The Planning Offices of The Presbyterian Hospital of Dallas were opened at 4020 Junius Street on July 1, I9b0 Mr. Be11 was charged with the responsibility of developing and executing qn effective program for the ?resbyterian Hospital of Dallas, bei.ng an on*the*site consultant to work wilh lhe architect and buílding committee, beginning the task of organizatíon by making contacts and selecting Lhe personnel to staff Presbyterian Hospital. One of his major achievements has been his work with Dean Gill, of the University of Texas Southwestern Medical School in drawing up an agreement acceptable to the Board of Regents of T'he University of Texas and the Board of Trustees of The Presbyterían HospitaL of DaIlas by which The University of Texas will accept The Presbyterian HospitaL of Dal1as as a teaching hospitaL" During the year 1960, the constitution of The Presbyterian Hospital of Dal1as was amended to permit eìghteen members on the Board of Trustees" The Board also continued to folLow its previously adopted plan to rotate the medical doctors off of the Board. 10, 1961, Mr. Karl Hoblitzelle gave a luncheon at Southland Center as an expression of the interest and high regard which the Southwestern Medical Foundation holds for the establishment of the new Presbyterian Hospital of Dallas. On the occasion of that announcement and by the grace of God at work in the lives of many dedicated men and women, the Presbyterian Hospital of Dallas was no longer just an idea in the minds of men. It had become a welcomed institution in the plans of the responsible cit':izens of Dallas who work for the advancement of medical care in the Southwest" On February The building was completed and the first pabients adrnitted in the spring of 196ó. Highland Park Presbyterían Church feels close affiliation for The Presbyterian Hospital because so many members have figured in its development" The following members--Dr. Frank Kidd, Mr, Toddie Lee Wynne, Mr. Robert H" Stewart fII and Mr. Toddie Lee lVynneo Jr.**have all served as Chairman of the Board of Trustees. Mr" A" H. Meadows gave the land in memory of hís wife, Virginia Meadows" l { I I I I I I t 1 I i { í .l .íi ,i I I i I . t .t 1 i 89 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 138 CFfAPTER CHATS XI WITH CHARTER MXMBERS institution is fortunate enough to have charter members sti11 is written" But since HighLand Park Presbyterian Church around when its history to talk with some of our charter i, ¡f.r""¿ in that respect, it seemed opportunememories of those early days. iãr¡.rr and discover what stands out in their Not every ít '! rl il tl ti In informal conversations with various inoividuals from this group, two present Church was not conclusions are inescapable: the size and scope of our ,ä ! Presbyány part of their thinking. Those first members came mostly from First t.riãn Church, Westminster Presbyterian Church and City Temple Presbyterian ðfrurcn and they did not expect to become anything more than a small, enthusiastic neighborly church, So their pride in the present Highland Park Church is rnixed with some astonishment at what has happened" f,,1 ilì -.:: tt' ' i. it, lt The other common denominator of the ol-der group that put into motion our rearly"chilrch[ is this--they had the tirne of their livesj It was fun to them: as one member said, "ES_1¿þ.9I was responsible for something." And it is interesting to reaLize ttlat ttris gleeful- spirit carries over until today as they and how they were met" There is no críticism of the present recall oi¿ "t"ttenges church for being impersonal and cool and organizedz they, without exception, mentioned that this was too bad, but unavoidable, considering its thousands of members" There was no sighing.for laughter while remembering. i t. ::ì!'.' ' '-l r'll il., i!:1 ,.,t the "good old days"--just genUine joyoUs Mr" Walter D. Carpenter. At 94, Mr. Carpenter is the oldest living charter member" He gave the men of the church (no hyphens thenj ) ttre main credit for starting the new church. He laughed when he rernembered that he and John Carpenter were business rivals--gas versus electricity--but in the church they worked together. He said that the Sunday School class for men was about as big as the Cr:rrie Class is now--maybe tried to see 125 every Sunoay. He said the sailors and marines (early'20's) the sale He thought Sunday" each which group could bring in the most "recruits" time it had to the (now but at of the land Williams Park) was a great mistake, be done. Mr. and Mrs. W. A. Fosdick" Mrs. Fosdick, perceptive and helpful (at 33) did most of the talking in a interview for an hour and a haLf! A native of New York City, she had "always belonged to a big church, so starting a new, Little one was quite an eye-opener." They lived in the same block as "Billy" Anderson (pastor of First Presbyterian) and went to his church for awhile*-but she got the impressíon that his church was so big he was glad to get rid of themi tel-ephone To meet their $O,OOO quota for the building fund, the women "a11 made notesrr--some for $ZSO.OO, some $ZOO.OO, on down to $10.00--and they were all paid off--except $tO.OO--somebody moved out of towni" t'We had a 'country "There were Other ways we made money," she laUghed, store'--Maybe11e Lemmon and I got in the car and went all over the strangest places, bumping over railroad tracks, to get merchants to give exhibits--what 90 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 139 good they thought would come of it, I'11 never knowj One man gave gallons and gallons of buttermilk, so we drank butterrnilk all day 1ong,l I' Mrs" Fosdick especially mentioned Mrs. Lemmon, Mrs. Anderson, Mrs. inge, Mrs" English, Mrs. Hortenstine, Mrs" Wil-kin. Mrs" Fosdick remembered that when fhe Sunoay School had some little tables (a gift of the Englishs, she thought) there were no children's chairs, so every Sunday she and Mr. Fosdick took five little chairs to Sunday School: two fol-ding chairs, one little chair loaned by a neighbor and two 1itt1e rocking chairs. The boys were of'ten rowdy, but Madame Zeek was especiall-y good with them. made One Easter, Mrs. Fosdick recaLls, the church was decorated by the personat Easter lil-ies toted to church by each lady who had one" I Mr. C" L. McNulty. "Last year I told BiLl Elliott this church was started as a joke --and it was"" One day he and Mr. Fosdick, l4r. Jim Forrest, Mr, Sam Weems and somebody else went to lunch at the old Mecca Cafe, run by John Atkins, on Main Street, down by the courthouse" Somehow the conversation got around to how big the town was growing, and how hard it was to get down to First Church on time. He said: "If we had one in our own neighborhood we could sleep half an hour longerj'r Somebody (MbNulty?) suggested: And a week later plans began to be made for a srrburban church. I I i r, I ,I ¡ Mr. McNulty was the Sunday SchooL's first treasurer--a I'Scotch treasurerorl The collection was separate from that of the church, and he nevrl let anyone know how much noney was in the treasury. But they were able to buy a piano, hymn books, and even drapes when Mrs. Anderson, ladies' auxiliary presicent, came to him for moneyo Mrs" J. T. Coulson. This charming and alert lady remembers, especially, the Wednesday night prayer meetings in members'hones, with the singing, etc. Here again is the recollection of the thrill of that I'early church.r' The Coulsons l-eft the First Church because it was "too big"; Billy Anderson, whom they loved, sent letters wíthout even being asked. Mrs, E. E" Crowell" I ! I I I I 1 She remembers that Mrs" George Sprague came all the way over from Oak Cliff to help the ladies organize. In the circles, there was a quota to be met in those days but each circle (of the four) could give to its favorite charity" t I t I In church, Mark Lemmon was treasurer the first year, but she and Mr, Crowell actually took up the money, stayed until everyone had gone and took it home to count, bringing it back on Monday. Mrs. Dan English" She was especially interested in the choir; there was a paid director, but no money for musical scores: so a play was put on to raise money" The actors had "old-fashioned costumes,'r and the play (whatever it was) was such a hit they gave it twice, which raised t'he money for the musical- scores for Christmas and Xaster music of that yeara One year Mr. Hogg was president of the choir, and he and his wife gave a numbèr of parties at their home. 91 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 140 in also remembers bhe christmas tree for the whole Sunday School stocka Alexander Hall, where there was a personal gift foi;;; 'niu'-|lu" Sam Weems was Superintendent aná Santa Clausj íng of candy and fruit" She Mrs. English J-aughed about the "bake sales" ove time al-l the fancy cakes sold, and the only thing 1"e píe, which they finally sold to a colored woman for t laughed about the kitchen--planned by the rnen: there like sinks in which to do dishes--very uncomfortablei the fact that none of the ladies had any money to gi some of them saved a l-ittle by 'rlaying-off" their ma said her maid really got it across to her that this butter, so she had to think of something else. ¡: ì t, i t; tit' 1ì i I Jones she was especially anxious that it not be forgotten blll M""-oüurtem others' had picked out the site for the church , and she deplored, with several that it had been necessary to sell off what is now Williams Park' Mr. L. M. I I ì ll lr Dyke. ì He, too, enjoyed talking about the preacher, was an old time Presbyterian-an excellent preacher, recalls Mr. Dyke. everyone was behind it, interested and e that attended the cornerstone-laying in the time. He said that Wurtem Jones han bought, charged a commission, then gave ' ,a and discovered night at midweek services, Mr" Dyke returned to his car and'told hirn she by he had inadvertently locked the key inside" t"". ð"t"ie came was glad she wasn't the only one to do that. One Mrs. W. W. Orr" Mrs. Orr's recol-lections were mos difficult to secure musicians and the c lead the singing. Mrs. Howard Beasley, Martin and Frank Vernon was director fo and almost at once were transferred to lfilkin's strong voice when he was pressed into service" Mrs. Elmer Schmidt. One of her most vivid memories is away party being given for the Alexander came home that morning from a camp-out w the morning hours at the church preparin the clinic getting her son's arm set and In 1933, when Mrs. Schmidt was Pre Currie asked her if the women would give him she didn't think so as they had alre she ask them ano inquire if they wouldn' that year. And they did,l 92 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 141 Mr. and Mrs" Frank Vernon (she was Ruth Martin) She and Frank were married in November af L926 and left town soon after" She recalls there was a certai.n song Mr. Fosdick liked so well thaL it was sung every Strnday" Perhaps it was "Make Me a Channel" of Blessing"--she isn't positive. Mrs" John Ashby (she was Litlian Cox). Her memories are mostly of Sunday School rather than ch,rrch¡ although she does remember holv pl.eased she was to have a Presbyterian church ccnveniently located--she had been going to Highland Park Methodist just becarrse it was handy" She mentioned Mr" Critz as an outstanding teacher of bhe young people's c1ass. Mrs" Dan C " Wil-1iams (she was Carolyn Carpenter) " Carolyn and her parents came to HP?C from C:ity Temple Presbyterian Church and, if her memory serves her right, her brother, John, was the first person--after the charter list was completed--to join our church" She recall-s the'l¡lomen of the Church having an apron bazaar at her mother's" Carolyn played the piáno in early years for Sunday School; she especially enjoyed Mrs" John Kizer's class in Sunday School. She and Dan were marríed by Dr" Currie, Mrs" H. P. fnge" Dorothy Inge was active in HPPC from the beginning--Ln fact she L-as participated in so many different activities it is difficult for her to single out just one. She finally said how much she had enjoyed being the Circle leader for a group of young unmarried girls, several of whom are still in the Church, She remembers that in those days the challenge of the new church absorbed much of everyone's time and thinkíng and each one felt the church couLd not do without every individual's utmost effort, t { j ¡t I I I Mrs" Cl de Welch (she was Shirley CaiLlet). ' Although Shirley lives now at Lake Dal-las, she has not forgotten HPPC--she, too, remembers that first Sunday at Town Hal-l when the Caillets were the earliest arrivals. Anr;ther special memory concerns the yor_¡ng people's Sunday School cLass, taught by Dave Hardy" Buck Wade was president and the two did many unusual things to maintain inter:est,, Possum and coon hunts were organized on the river bottoms--Clyde Welcir brought his dogs--and more than one rcrnance flourished. fn fact, as Shirley recalls it, she and CJ-yde were the first couple to marry in the Alexander Building in June of 1930. ) I t { 1 I : Mr" and Mrs. Georee Wilkin" Since George and Mary were ttyoung-marrieds" when our church was formed and he was even singing in another church, their recollection of those first days are hazy" Befo¡e too long, however, he was singing in our church and they both speak of choir parties in the Hogg's home with enthusiasm--especially one in costume " Mr" and Mrs. Raleieh Hortenstine Raleigh and Helen Hortenstine had a rich store of memories to share with us. Looking back even before the beginning, Raleigh mentioned that a committee rnet first at a downtown hotel and engaged l4r. L, A. Coulter, General Secre tary of Yrt4CA in Texas, to assist with the organizatian" 93 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 142 tThat first $7,500.00 provided by the Extension Board was given as security for the $15,000"00 down payment on the property" ltthen the first el-ders and deacons were seLected, Raleigh was elected treasurer and Mark Lemmon secretary" Raleigh wanted to change, so they did (to Raleigh's sorrow, he found or¡t later). Helen told about the Sunoay when the members coming from First Presbyterian Church were formally dismissed from that congregation by Dr. Will-iam Anderson" She said she was in tears--because he was so direct and finaL about it" "He tealLy seemed glad to see us gorrrshe admitted" She recalls how members of the nominating committee of the Women of the Church each selected the office she wanted, Fortunately she had no recollection of dissension--all were enthusiastic about the new church, After the Alexander Building was finished, there was no noney to furnish it, Ten members of the new Church went to Republic National Bank and signed a note for $20,000.00 for the furnishings, Each one's liability was limited to $2,OOO"0O but the note was paid without calling on the ten. (Þ1r. L, M. Dyke was also one of the ten who signed that note. ) Helen and Raleigh both spoke of the first Sunday the church met at Highland Park Town Hall. They had risen early and hurried young Raleigh through breakfast intending to be the very first ones at the meeting place" But when they arrived, sitting on the curb were Mrs. F. P. caillet and her l-ittle twin girlsJ It was from Raleigh that we learned the valuable little book which summarized the first five years of Highland Park Presbyterian Church (which has provided much information for this history) was prepared by Harry Boyd. This concludes our story. It is a thrilling tale, and we give thanks to Almighty God for His guidance and bLessing. T?te achievements of the Highland park Church through these forty-one years are certainly a tribute to the faith and dedicated service of those 190 charter members who saw visions and dreamed dreams" "Other men have worked hard and you have reaped the result of their labours'l (.¡ohn 4:38, Phillips' translation). lìle are not content with what has been accomplished" We know we shouLd have done much more for Christ's honor. We know trthere remains yet very much land to be possessedr* and so, t'forgetting those things which are behind, we press on'r toward greater thíngs in the future" May God continue His grace and favorj 94 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 143 PROGRESS Yea r OF HIGHIAND PARK PRASBYTERTAN Additions to Membership for Church Year All Contributions for Church Year Total MembershiP on December 31 By Profession L927 t928 L929 1930 $ 14,333.00 36 ,549 " 00 5 2, 340. 00 43 ,664 "OO 1931 34, 695.00 L932 36 1933 28,796 "OO 30,605 " 00 32,92L"OO L934 1935 L936 L937 1.938 L939 1940 L94L t942 L943 L944 ,002.00 l_13 (ls) L67 87 (24) (6) 110 130 67 (33 ) r25 ,506.00 38,145"00 36 ,911,00 40, 83ó. oo 85,452.00 96 , 83L.00 95 , o4B. 00 73 , 493. 00 331 (loe) 161 (38) (4s) 343 L946 L947 212,511.00 343 438 35s L948 23O,4O2"OO 1949 1950 1951 266 , 859.00 290,970" 00 317 397 439,050.00 579 L952 562,357.OO 1955 L956 L957 1958 1959 1960 52O,267 "OO 504, 478 " o0 555,448 " 00 (4-1 to 3-31) (Calendar year) (s4) (100) (e0) 532, 700.00 678 469 rr32"49 793,6'83.99 823,642.OO 7 59 ,754 "OO 452 389 407 398 L964 1, 538 ,749 .OO 376 1965 L1,209,72L"OO t ,o77 , 871. 00 "OO ( 108) (Lzs) ß2) (128 ) 886 ,7 86 . 00 1,098,697 (e7) 420 4L4 418 t962 L967 (tzt) (116) (118) (108) (116) 196 3 L966 (e2) (202) 549 361 504 396 77O,086 "23 (100) 108) O4> (ee) (sz> ( 433 794, 115.00 839 ,733.00 196 1 797 868 911 (13) 130 L954 (20) c42) L43 77,842.OO 1953 1953 752 L47 156 191 301 100, 76 8. 00 164, 877. 00 L945 646 (s2) (22) Qe) (+s¡ (22) (34) (8e) 61 t27 36 239 346 499 573 (L22> ( 104) 324 364 (L37) 362 ( 102) 1,015 1,090 1, 185 1, 330 L ,577 L,677 L,944 2,O42 2,LLL 2,376 2,629 2r852 3,078 3,2L7 3,4L8 3,673 3, 809 4,LO7 4 1276 4,566 4 1623 4,780 5,001 5,LL4 5,257 5,423 5,615 5,789 5,949 6,O34 6, 110 6,208 6,3O4 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 144 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 145 -¿ Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 146 L s7 liötþsF lE^flù / U¡lLl.l'tr) HISTORY DIVISION ¡.1,,tr!l^ 000500 CTX Yi313el,?0 $çP R èê5.1,7hq N0b3b0é7 00¿ | itn-2'4Î i s iF-îì Dallas, Te;'lag FS¿? FIRST FIFTY YÈAR,S HIGHLAND PARK PRESB DALLAS PUBLIC LIBRARY TEXAS AND DALLAS HISTORY THE WHITE HOUSE. wÂltHrNoToN Àpril 22, L976 rO TEE CONGREGATTON OF TEE EIGEI,A¡¡D PÀff PRESBYTERLA¡I CEI'RCE It iE a pleasure for me to join you, your pastor, Dr. B. Claytoa Bell and Íry good friend, Billy crahaÍr, in the celebration of your 50th anniversary. I think iÈ is rrell to reeal]- as ee celebrate our Bicentenníal year that wealth and ¡rower do not measure the greatness of this or any other nation. Our spiritual principles and rcral values constitute real r¡ealtb. You have denonstrated toleraDce, understanding, aod love and by your dedication and hard work you have proven Èhat a peoplers greatest strength is its oxrn faith. I salute you, and I join in your Prayers for continued spiritual strength in the years ahead. /fu/4 2'{ Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 147 A HALF CENTURY 190 DEDIcATED and far-seeing Christians signed their names 50 years ago to the charter that founded Highland Park Presbyterian Church, May who served as minister until 1932 when he accepted a call to Birmingham, 9,1926. No new Presbyterian church had been formed in Dallas during the previous quarter century and none was to be established for another 20 years. Ours was destined to become the largest congregation of the Presbyterian Church, United States. To a great extent Highland Park Church was the creation of men of vision like George T. Reynolds, elder of Oak Cliff Presbyterian Church, who perceived the need for a church in the north Dallas area, Dr. Homer McMillan, executive secretary of the PCUS Home Missions Board, and Dr. H. S. Springall, superintendent of Presbytery Home Missions, working with groups such as the Presbyterian Extension Board of Dallas and the Organization Committee of Dallas Presbyterians with Henry R. Davis as chairman. Throughout our church's first 50 years of ministry there have been so many devout Christian men and women who have given their time and substance to Highland Park Church that it would be impossible to list them all. But there are some persons who should be mentioned here because of their significant contributions to our church's founding: the Organization Committee oÍ 1.926, composed of Henry R. Davis, Sam Weems, Mark Lemmon, J. T. Coulson, Charles R. Teeple, John W. George, Raleigh Flortenstine, I. S. Pulliam and Wurtem D. Jones; first clerk of the Session Harry F. Boyd; first chairman of the Diaconate Henry Davis; chairman of the Building Committee W. M. lVhitenton; and the architect for all our buildings, Mark Lemmon. Two important steps were taken early by the organizers of our church. One was choosing the name of Highland Park Presbyterian Church; the other was the purchase of the presently-owned property (paradoxically located in University Park) as the site for the new church's home. Highland Park Church held its organizational meetings in the Highland Park Community House and later in Highland Park High School, now Middle School of the Highland Park system. It was not until January, 1927 that the Building Committee was named to start planning our church's pennanent home. Mr. Lemmon was retained in April of that year to begin drafting plans for the first structure. Contracts were let for the building in December, the cornerstone was laid the following March and the first service was held in the building on August 12, 1928, only two and a half years after Highland Park Church was organized. Later this first building was named in honor of Dr. W. A. Alexander, first full-time minister of our church. Highland Park Church has been most fortunate in its ministers. In the early days, the Presbytery granted our church's request that Rev. E. C. Scott serve as stated supply. Then came the call 1n7927 to Dr. Alexander, A unique situation ensued during the following S-year supply pastorate of Dr. Thomas White-Currie, for whom Currie Hall is named. Not only did Dr. Currie perform his duties with our church; he was also president of Presbyterian Theological Seminary in Austin. In 1937, deciding the double responsibility was too much for one man, he resigned his Alabama. pastorate. A major milestone was reached by our church during the five years that Dr. Henry Wade DuBose served as pastor. Dr. DuBose motivated the congregation to build our present sanctuary. Dr. DuBose left Highland Park Church in 1942 and for more than a year supply pastors served the congregation. Then in February, 1944 we called a young minister from Druid Hills Presbyterian Church in Atlanta, Georgia. Under the inspiring leadership of this minister, Dr. William M. Elliott, fr., our church saw its greatest growth in membership and Fri.g both for benevolences and expenses. Dr. Elliott retired in March, 1973 to become Pastor Emeritus. The congregation then called Dr. B. Clayton Bell from the First Presbyterian Church in Rome, Georgia to become its senior minister. In addition to Dr. Bell and Dr. Elliott the following comprise our ministerial staff in 1976: associate ministers Dr. L. M. Kennedy, Jr. and Rev. William F. PruitU and assistant ministers Rev. fames B. Bankhead, |r., Rev. James E. Simmons, fr., and Rev. fohn F. Tolson. While figures in themselves do not offer a true gauge of a church's ministry, they nevertheless reflect a growth in sewice. Highland Park Church's first budget in 1927 amounted to $12,175. Even then oui church was much concerned with ministering to the needs of others, and from that small amount set aside $3,400 for benevolences. From the charter list of 190 of the year previous, our church had grown to 239 communicants. Growth was steady under the stimulating leadership of ministers and members 683 communicants in 1932 with a budget of $34,700; 1,800 - 1945 with a budget of $164,000; 6,200 members members in in 1966 with contributions to all causes amounting to $1,078,000. Today our members number 6,500 and the budget has grown to 91.,250,650. From that first $75,000 structure, Alexander Hall, our church buildings and properties are conservatively valued at more than $5 million. Our stained glass windows are among the most magnificent in the United States. What of the future? The dedication that characterized the beginnings of Highland Park Church is evident in 1976. With continued Christian commitment, our church can look forward to unlimited opportunities for outreach around the world, and ever-broadening services to our community and members. CfX 1ll,3eL?0 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 148 R wILLIÁ_ùf M. ELLIOTT, trR 4I40 MYERWOOD Lá.NE DÁIIÁS, TE'<^S 7õ234 Dear friends, The Highland park presbyterian Church has rendered a magnj_ficenÈ sèrvice since its organizaÈion fifty years ago. God has made Èhis congregation His instrument, and its redeeming witness and influence have gone out across this land and around the world. In certain aspects of its l-ife and work it has been an example and inspiration to countless groups of Christians. l{e thank God for thj_s church, and especially for those individual_s whose vision and determination made its life possible. "There remains yet very much l_and to be possessed" (,Joshua 13:1) , but we are on our way, and under the power of the Spirit we will win even greater victories in thè years which lie aheao. Let each individual- who shares in this churchrs life rededicate himself or herself to the glorious cause of our Redeemer. The world's need for the Gospel is desperate, so we must share our li_ving faith with a1l men ever)zhrhere. God grant us His direction and. power as tn/e move aheao to do His will! Y, wrLLrAM M. ELLIOTT, JR-, D.D Minister 19M - 73 Now Minister Emeritus Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 149 B. Clayton BelI To the Members of Highland Park Presbyterian Church Dallas, Texas Dear Friends: Fifty years ago the 190.charter members had no idea that they were laying the foundation of a church that would become the largest Presbyterian church in America. Our size is only a part of our significance, for the urinistries through people, stewardship and service have been truly great through these years. The past is now a foundation on which the future will be bui1t. These last three years have been a time of major transition for the church. the retirement of Dr. Elliott, your call to me to be your new Senior Minister, and the building of a new staff have required of you major adjustments which you have made magni.ficently. I am proud of spirit of this congregation, and on bèha1f of my lhe great tamily, I hTanÈ to express our deep gratitude for the warm recepËion you have given to us, and for the friendship and support you express continually. tlith our first 50 years behind us, v7e now have ner¡ opportunities for serving our Lord. The enlargement of our program and ministry, and the nelr surge of growth and interest indicate there are great days lying ahead. May our Lord's faithful help and guidance in the past inspire us to rener^7ed faith and cormritment as rre accept the challenge of the years that lie ahead. Faithfully yours in Christ, B. on Be1l C B. CLAYTON BETT, D.D. Minister 1973 Highland Par\ Presbyterian Church 3 82 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 150 1 Universí ty Boul evo r d . D dllds, T exas 7 f 20 J 4't'. ^3.1 : First clturch edifice, in which first seroice wqs held August 72, 1'928 ,l¡. -f I *rl ì b è ,t! ì-- t I : t ß j : Ì o I k s q '-t ,+!.^tç-- -.'-¡Sì F-;'1¡,: Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 151 ru ù t\ Mrs. william F. Pnútt ztlrcn they became our misstonarrcs to the Betgiøn Congo in 1945. Wíth them are sons Billy and Bobby' Reu. and Bttilding utltere our ligh school students attended Swtday School l11 -! t +l I Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 152 in 1946 -..-z'-- .-': rr¡i O) ,v-- \úl Ot H Ø L SJ o U L q) Summer eaening outdoor seruice, Iate 7940's q) (J U L U U I Ø q) \ q) SJ ( Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 153 l' i ô a d The church in 7950 o \ ;Ð ! (o (¡ì Ò 3 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 154 The church in summer Âtanpuns at¡y lo nuayuy Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 155 4i'\ / '-'^'4.?t T -Í.' ' ..t ' I h ( 3 v- ri ffW - : l,- ,- .il The church in zuinter fiu aLll wott t¡ttru¡c aq¡ Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 156 \ I Architect's concept of the church of the future + * l¡J + + a\ ,À UI 0 ã; (-' Z 5 ¡l (:j (, lì ì ,n \ 0 fi .f, - t-i t't r{ (1 ti. ,l ¡ ll (o H \, (o \ o\ 0 T .0 'tIat4 ,. . t i,' t'. ' :'. |- :1 '(._ t -,O . -)- ,?) Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 157 EXHIBIT 3 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 158 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 159 the be rhc Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 160 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 161 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 162 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 163 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 164 Li . vey :l be Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 165 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 166 ::: a .: , .. of ' .: ., rl3ay a fI¿ e ,','.1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 167 l 8S :' rnannert: Approy*l of the amendirent 'recomriren1... Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 168 EXHIBIT 4 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 169 täl¿'l t5¿//" ¿/û 4-'uìu'e*zla' 401 t 4 3 :' f;f,ìlD Pon ¡gottD 58tr1, Atrb r*,Ir" t9¡Ïi at t¡3ô ôfÉlort t.¡..D,c.rhitclÊ, ccurrty clrpE ¡t c.ó.65tthr åúpil!y. RBCôñiE ûCl!¡, tçr. ¡,1,1 Ð:õ D.C.ttlltctrJloô¡¡dBr Ct èrk ,Gpot.l. i I a l I J t ¡ t l ! å ¡. 116t00..,....,....,.. r. c.3¡t¡¡!nr1 ltlB SÐ,!g 10! dlR¡rÂElT GEa ,08! I. C¡-Þ.F88?Èß rr rt eP tEfÁss I O0IrHY 0[t Drttl4S¡ ! 1 ty ÍrFcD j,l,t$ttrsr ð0r ¡úr llEË l lbt Ir t.C.Cllìirù" 6 siÞgJo rr¡r. ûd th. o.uÃty ef f D*1'rr4, 3iå1€ at tgñó'foF ôDÄ rn ô.sii¡trottÞû of th. r{¡ ùr Firlt fro rìc{u¡¡Â drú to/ro0 I* l$6¿.å00 'où, ùorrÃrê. to !a ?3rü. r"nÀ oGq0Ìoè tÕ ¡c DrlÀ, t¡ Jotu r.c*¡rntrrr Bür¡l I l¡. Boyt¡ ìr.¡¡,llllitontorr !trtít..Ê d nlehfr¿ô prt fltibrtârlsô CbDob ro folloc¡ ) FIf :?an ?hôqñËá ÐotLBü attô.rtr.oo) oùrù !¡ t:Àñtt 4 ÞrlÀ by qhnr,errr 3Lè raceilt of Fhiêb ¡r, hôÞty r,ot,Þúlaùg6¡t. : I !¡Ë Òroûutlôü ¡¡Á dolfvrrt ùy grî{to.ú ot thÈlr f,lrr clF I tâ!tr flril IjÉ ûDtâå I¡tùå Ðll! ôt $âv!ñt, tÍrr euíiso[ ¡þftu¡ I lf7t0o.Ool .8dh, lnln( f atuc å1ú Ps¡rrùlr ofir þôr ùÌñGc. foqr â¡ù t$. lDur åltor ¡lstêr ìroårllç lît{crgt f.-st {I d úsl. ut tha ¡tit ol sore¡ ¡rr ocut ¡,or áE¡rr. Í,¡õi,r!lo 6õt-cDúl¡rj åe¡a ,¡otos ÞranttlÞc I t fut û:i091ÒÉrdd Áât*¡t¡ ls¡ fr.r.Iuro to ,ot át rmtd¡.¡-60nÈ Òf t¡t€f{rÈ ¡Lêfær, ,hr¡ rl¡¡ oi nlt ñÞ. ot selô Ttå¡ ihôh dl$, el lìûFthcr JEþr1lttrl, tôf te! p{! coìg ètto¡rty,s fsrs ln thâov{tr rdô" oÉ el¡l onc of thon, ut l¡4{oil In tà! ì¡trtÉli qf 8n ât?ôrtì!¡' ÍoD T ¡ r L 0ô1 ¡3ottoa. Eoln8 tBtbÒr j rl.lh. to ¿oÈtr C.ÂrÂd, ôófllìû ùt I Dôoà ot &ú¡tof áfrÄ d¡ta hrro- trlot.r. lt :, u¡ldorltooñ âñ¡ kgrooal !¡¡t øra¿i6r harâl! Þ¡ â¡Et Ir¡ I ¡al øur åtrd. hôl¿ðr of thr åtro itoocrtb?il ¡Éìö! rlll ñr.i¿rô t¡rù rìô llar rocqrl h6 tþ Bùori d"rôttbûå notlt ¡cls fllt of tL. áb-d:rlr¡ø of tIè bsr.tüftÖÏ c,orcribaal,r¿¡nrt i ¡l ot ¡ t¿tl¡ of $rO.(þ t r tmnt toot fop lotr t¡ßlld ¿! Untrè"¡¡!¡r !mlsra¡ô.. sd ,¿S.oO Per fæt foî r'l"öc. otr lóir o! rtrôðtr ottor rbú u'tv.rÞ'rt !or,'rt{) ÂÒ rot îo crtêÐù ðrqìi¡ thrl ä,8 J¡ol. fùtr r¡r,rtrortr Jû ìróe¿ upon plrt tbt, at¡, cgfü.t n¡on ù.tloðr Srihto¡ ¡n{ 0ratù.o bc¡c!¡ ð¡ô !¡oolt a¡y rtlËar¡a D? d.â¡lr.rl óìh9r $ûn i6co¡0.Jng ta tba ¡r¡t {,0'ôrô Bpor¡ apJrrgrærrô r¡tb ù!0 0!î¡101 0¡ i¡fr ;c.çr ¡FJ És¡t '+r¡¡florory ba Èaa¡. , to|'oì¡ob ntêrda. , &1d tlËô aôtÊt ù,.,rhl r tlðglc na. ûÉr4bLe .jo thË olilc.¡ or !!.û.ttl¡.rt, åtl oÉ rrid ígtcÐ btl_0g ¡lra fi¡¡,ibtâ 3n o! ùöfoä. ^rd lato ûÞñtlti 5o1t àfd' Coìrotcû,rrd ìV th.rc F¡cü.niô ôo clofttr sol.l È:l Crnvrt ¡uto thÊ Èâtd. Jolr! (,C¡¡pcnte¡. J.l"Co¡tton. k.E.hr1a, Aorçy t. lorðr hd [. !L t¡rtoaio¡' r¡rú.sì?a! af tra [is]!ônô t¡rk ¡n.ù¡n¡¡is ühurÀ e, tha ; : CouEtt of gl g¡¡r¡, rll il¡¡t Ésrirfu,otr tlrêt ôr êl ¡.¡sô ¡rLEâ, ¡û!ôcl 'rlbs.gtsro i ruÀ bclag rl:raiã{ l¡ t!¡ C+¡¿ty ú ¡¿tl46r St¿t. {tr t rurf ¡r¡0. toi.[t !:prt gf thr üohn I gou¡loo¡ smey. ôs fo¡lort ¡ DlÊfl{TiHç {rt r Ër¡lr ,ü th sori} l¡gL of 0trlrarstt, : rbfdh no1åt I: tÊS{ fÉrt t¡lt ôf !,hö l¡t!!o0c!!oÀ of o¡it SqÈù ltro 6, ltBt"rlrlt¡, ¡Þft{.r I I ,ì -.,, . , .. -.* A5 HPPC 0301 0 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 170 +0-¿ ?ôDlôvrti tlút¡ ttü Eart lle of g.srtob 8orû¡ ffilcB, l:oä Éllr t.r r!êb do¡ftr. sûlô fid& tñctÍ Þ.1¡Þ l1 rtn. :?. 6&t *rot to etr thi Íortbrç¿ù ûonof ¿¿ tb¡ t,Ðrot l¡uåß* Sóqtl¡ rc {cgrôoå bêlnc liIB8Cß. llotlh 69 dâE oor l1ô ßû. 8. t?Þ..$ f!"t to û shkê lr låo flcßl ùmdutt lr.ú ollhr D¡ttÂt od¡ntrt CLnb Srouhtâ. cÀ¡t stu$¡ ¡afà6 rloo thê tro..[hraËt c(rru ot tho :Érqy ¡û¡tr3ü 1r¡ct¡ ftlE*cg , FÞza\ zt oG5rors fO rlnrr!(Ê ¡aüì lOå l{+l [o [hc qe6t naÞt!trlt.¡qrthçcsl corn.,r ot tho ne!lâô Cóurtr¡ clut omrr¡E' sl¿ üGntr t"fn6 ttr& l¡tbo Sq¡Êh ¡ln. oi lìß UsirÈr'ittt Þßrl Àildltloüi t^tlßfltlt. túllding lhG$tt su¡trh hfNt lrst J lN uf (ha UÀ,.rcrrft¡r lôrx litdJtlon u lÉLl#¡i ¡lorlb 89 drËrorri t riÊlr¿ot. ,ås¡ ñll leot tú I ooF:¡f¡ lrt:¡ o6r¡iËr , f î¡ jl,lc CffiL; fl&¡ltE ¡ottù ó ôcgraùå t¡ a1¡qtô6 Brlt tÒllo*r¡t tb. croasi¡¡g o¿ntcf, îqtL trâoE l _'l ¡¡nc 0f f¿¡¡16 C.eâl ?tS faå¡i ltBtl:Er !.lrtt¡ ¿o ûcgrár8 !0 lirNtâs ilest |rn f^b. fcrÈ tô r corrrri 9IR¡IE, iltsl 16È"!r¡8 rbe ¡frruù ol tü¿lle c?(ål ünð fôllilJng ìüË $fttli ùcuratst llt= óf th¿ t|Iletr*tì! PA'R ProDêrtt, T11 *n.è tô Èhô 01ieâ o ì6Eiel:Dt, Àñ[ oôþLsltr1rrê 9.Yå ås¡êf üf là]it, rþr.o or lc¡i. Ûflng tttö sûlit n¡oIa ty i¡ltl3lèltêô tô t^hs ¡¡¡b.tt¡l IatçatneDú to¡râ¡t bt'ics D. tocrc. l}l¡!!óå. ¡¡ th¡9taâ'û Doólt âètÒrl SeptülÈt¡, Ltb¡ l9el. od :'srorilrt ¡¡l'oluæ 903r rsra s12 ,t tlr rcÒùrlß et î.F[$Î.ârÉ Dêêd3 of D¿lþt couffy, larar to E¡sE rül 10 [oLn thr ibo[l orùcrl.ùcö lr¡.i¡siË. tå8tihc¡ srth â¡t âtt alngolar th€ !'tBL!s r\ail åÞ¡ortâl3rFcs thc¡ô3o ln ¿Î¡fft{tå btlongfñg tl 1b ¡h6 ca¡û Joìrr f.esÊponfêr. M.rrt ü.þ6¡t. td l.ltFhltôntou. îñrtfôo ôt lbó E1(hl^rü Prùrb lterb¡rtrërtgn ebu¡{b t¡rôxr sr¡coËr¡cls uô ûñsigh6 lêrotêt Àäô t lta hbrù}y blt$ lyscltr üV hôr¡8. É¡È¿iùrrs oJd Êiùilnlstrrtôr., to tår?ílnt ùnt 9qrwêr Dâ{ån¡. â11 ao(ì Fl¡tggls ìÞa ìoçt l¡åñcl¡ of i'wllo CraÈk 1tì6 Þr.ñtico r¡n(ò åhÇ våiô t$hn t.!Ú¡Ëötsr tbrlÍ!¡. toy{, u.d t.il.Íbltc¡tðr, ¡¡69¡366 6! à11å latró FGk lræbttóFjan Cbu¡ot¡r,loÇir g{coôsoosÈr aEù Fôrlc¡o. à811ßt st.FlÌrårson {hônröatdr ttr5f¿Ìlt c¡¿i¡låå ' o¡ ùo ültlE tlìc !uü. sF ¡W Þ*i lh6 ñof . 8at if iâ rrl'!Ò¿siy tGs.A üa ottlul3t..t tù¡ì lÌ¡ ?çAiloctè tiéD lq &Èôln"û ð0¡lrut lì1ô tbotG ¡täOc!$e{ }roFotàtr prd¡¡ct Aaå ll2rwClontal' únl¡l lba âbùrc ôoâo¡¡Þôd ,otôs, Ânô all lnt.mrt lbotoo! $t lttrly prír uoqÓFlfn8 to thötl. laoc anrl Èarìo¡f 6tto(t ¡r¡J FotilÌrg i hhcD lhlr ôêoô uhåIl baüccc abaolÛì! ílÍtl*B ry Lanô åt Döllui !ç5e. tb$ gêd dov of Ì S?FtmlcF. ¡.û. I .J 1916. r. q. ¡tl 0¡n06f3. îsE s!ÂxG qt lEf{sl I Dû¡.SE ¡!Ð, !tâ üdôrðlÉnld. è llolsy la¡llß¡ td CJirlfY cP Df.I[Àsr erû lôr sBii Co{Àtt ûd s'.tl., ca shts ôlt}er:þÉllt rFPsu¡oô ¡'c'0f lkri' i Eln$lr ôânr t¡on .,o fú to bê i'ãê pclsôn l|iüâr J¡NtÖ ll Eûbrltlbod, to lÈð lotlßDlBit l¡Dgru¡.ütr ill¿ ró!ûælêôüoit toEc tht hõ âxéèBloô tht 9À!ô for t¡+ y6r|Þ9ôå rûü Goñ;f(Þ!r¡lloÞtlcrcllt Öfprlnaöûr 4rtEr uþtt Àr SlliD ÍllD sBA! oË tFFics' lrìlr thc Ê? da¡ ol úepf." r"t. tg{f* þtt B"l¡orÎlrt' {r,.9. 4 !, rl-ki,.Jrr 5otÂrt fqbllcr ¡û ôriô :tÊ lcltnc Õounty, fcras' } ! [q .. I" '. A6 HPPC 0301 1 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 171 EXHIBIT 5 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 172 ) OF C ::r"A-. ¡.r-lftll¡',L t ifrifli!û iun-a¡ June' ì-2th, 1927 ] *1¡'-' of the Oon¡r;+gatlcn duLy cal:êd ñas held on '"he l2th day of Jr¡re, L927, lÐ consider the acvisebilíty of instructi.ng the fn¡stoes to execute ¿ bond en(i rorùfis.?e to ühe J!<ecutive Cor.¡nlttee of Ho¡ne ùlisslcns of tJre Presb.',ü,¡rlan -hrrch ln thr: U. S. A neetin- ln bhe su¡n :f Þ7¡-OO.0O. Ìhe ¡astcr, Rev. rr1 å. Alexander, acted as ¡rroclerator and in the absence ;':'on tbe eity of Lhe tjlerk of the öessiorr¡ :T.'s. - nly rrâ3 aplointed s?c¡Étåry. ÈICer Ielrls ?. Carpent+r sbe'¿€d tl-¿t or¡r church has applied to satC iixecutlve Com:itüEe for aLd in said sr¡¡¡ ùo enable us to erect anrl prrìsêÊs a tiouse of ,'orshLp and ilat in orde:r to obbein sucì: aid Ln sur;h gr¡üul'r't it nould be nsc'¡ssary r'or the iruete,rs of the Ohr:r'-h i'c execute a bond in eaLd srn of S?r500.0O, agreeLng thaà fn tJre errent this church shorrld cease to be connscr,ed ¡rith the 0;neral Assenbly of the Presbyterlan Chu¡ch in tha Unlted Þtatesr or its corporate exlstÆncs ceas?, or tihe rnortgage and property be alier¡ated or abarrdoned, or the Housâ of tforship be allenated or abandoned as a Ílouse of Vforshlp, ttren in such case said chr¡rch sha,ll fortb¡vith refi¡nd ar¡d pay saLd sun of mnegr back to eald E:cecutiw Comrtttae, end that for the purpose of se0urlr¡g the pqyænt of sald srrn, together ü.th intarest, safd Tnrsteee rould have to e¡cecutp a nort6age to õaid Erccutivs Comfttee on the tbree end a fraëtlon acres of la¡d in tåe Ctty of Universlty Farkr DallaE Corurüy, Texaar on rbich lt ls proposed to enect a House of liorahip. Ànd seíd ÊIder l¿ris f. Carpentær mved that tbe Tn¡stæes be authorl.zed and Lnst¡ræted to executæ sr¡ch l¡nd ar¡d uortgege. Tlre uctfon ras seco¡ded by Deacon Sau R. {eems. lîereupon thc motLon so nade ard ãeõonded rag stated by the ¡¡oderator and ças unarrinousþ cemLad. For the -rrfor¡¡atfon of ùhe Congregetlon, Treasrrrer ilalter Hogg etatæd t¡¡åt on tùe previotts Sturday JO ue¡nbc-rg had pledge $t5r86O.OO üo the fund to be rlsEd for theerectlon o{ ühe prqpos€d houee of rorsh{p. The me -ttr¡e then adJorrrned. /"/ w. s. L€ulùrr Secreter¡r HPPC 03243 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 173 EXHIBIT 6 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 174 John Stccu tkronry of State f.'ot ¡ncrtiorts Suct ion llo.r I3(197 l'û Ar¡sli¡¡.'lèsas'rN7 I I -.ì697 ()fficc of thc Secretary of State is a truc Seøeta4' of Sture ul'T{rsas, doos hclcby' co rify llut tlre attaehcd bclorv as described ofì-tce in dti'* lìls cap¡:of cach docunrenl on 'Í'he urrtersigned, c(1rr(ì01 a.s I,II ¿\rt icle¡ of f ncor Poration Àr't iclcs ol' Amendmenr CI I ] .AN I) art<l PRF,SI]Y'TËR I ÀN CI'I I JRC I I Filing Number' 50iÔ901 PA lìK l:cbruary $7, 92ål January 11 9?8 ln lcstimony rvl¡ctcolì I luve hcrcunttl signc<l lìly nanle offioìally and ,uusod to bc írnpresued he¡çon the Scål of Stute at rtty oflìce in Åustin' T¿xas on Scplclrrlrcr lfr. ?011. \-.'\n lohn Sleen Scc:rr-tary of St¿te 480 HPPC 03085 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 175 - äEo (f) o O È 0- T CHARTER e; l¿ar 4-t+*- --?. -*-rgz.lResorded Book- P age--.--- F ILED FILE BOX NO. Cr+ì2t-!l¡ü Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 176 ¡l 'þ t{ Ì I I -Æ w it f- \Ë j f ô q f !j: l f c h t I ): "î I l" I u, i { ì! ¡ -l"r fs.l ¡À ;È rÌ { ( Ir íþ It -;b IT ïn tr ,1 I I t ,r A82 HPPC 03087 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 177 srÀ'f!,; oF Î1iiôS, crr:r$Tf 0F lt l.lÁi hì ?IIASE }ÌEEbttr's¡ ùhùt' Ëc, !l' Àl'lloyd, f. X. vlll!êrtü n. f,. ltsvia, .;Jlür ti, (br¡rrrtrlor. nñd J. $¿ Cctrì*ort. Roiir:5 jcr ¿rrtl ôr,,,:lulf ot'ihö lliUhls¿¿ ¡lrrl ftufìtytûrlt¡ Church locsturl l:r lìr]l¿r5 Cor¡:ìl:y! Tvrll, on<ì ciûß .Il¡Iy au'.!'ôri ¡*¡! lry l'lrq a(tr)Crr¡5ütl'rÍl of uid ¡(t{o ¡Lr. ,,Utf Cl.rrr<l!, far 1ìiio 116 f,urpuo,r, hç¡rrl¡¡r f'cl^r, ûnd crdo l;o o cÔrpol'ât¡or. urtli lçiìy ÞôlilJê nc ntthn¡i¿r.i uh(tôr til:le 32' Clrtl,l'ú¡ l, ¡lrticls l30l of llìo rrviled ñtutl¡to$ í¡f ÎËr¡E ÐÉ hborÙun'lot' fo)¡ot'Ër I lîo r*¡nc sl"':hu êorfn¡"nt,itrn lg ìltBhlurd Itrrli l"'cc- byl:<rr1*n Cll¡rch. TT Íìtc ¡,lr¡o:c f¡¡ vhlulr it i¿ forrld lc tlrc atr¡r"rtt of ¡rrl,lic rofrhi¡r l6*rril,¡ l.¡,ô mínl$¡j.l.fioo arf llxr lrrd$l':'il{!rión 0hr¡rch, l¡t Îtø plrca nlröro ils I'utirlt$!r lg lo lrc l,runr¡rçlo¡l t* jDalla:i', tl f{¡ llll¡ Ontrr,tY, 'l'nla n. JV 'llrc :crn fa'r sh¡ch f L l¡ l.o u¡i$¡" Iõ f;fl;y yoè¡'¿' llro Qf trut¡hoc¡ {o fivc, ¿ñd tho nÀl{ét ù¡d rocitltn0¡.; fcr l,lrQrc vrlrô $ro '(uìlrúr alt¡(ini;ód frrr tlo j'írsL yoor¡ of.r üs follcÂvs, to-wlt: ll. I' itoyd, llrlle s lhljua 6cirrly: i?. llnhlt(Ñn Cor¡rl,y; lårÊr4ül;cr, t¡rllûö (iountyi ¡rtld J. li. !¡. DúYts, nÈllt6 Corrnty¡ Joirrr T. 6or,lrcr, Ußììå'o ll' Caunty. ., '!Ìrì n aorporrt,t rn ìtts no olptiol *tôok ol.ìle. Lhttr th6 lot cmod by tlio Churoh t¡¡ìrìn $l;lt)h É Chufêtr Ùrlt)àitg ts bo l'o ercît;odr ol tbo e¡tþslåd v¡lu¡ ol 9s01000"00. 3-l A83 HPPC 03088 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 178 ST¡rtS ô 0l' rrr!! ?1,IÂS âf. ÄluåE t I,rn tlrl¡ d¿y, J¿n" 3¡. tg?t Fórsô¡ç¡ly ')rçfo¡o ¡r.o lf, rl,. Eoyd, N;N.n[,El,ou, lt. ft. Uûvls, cn.l J. ¡rrr tr¡l','.crllrrrû rlohn appcnrod K. Cerpcntcr, î..Coulrot, and txln6 krroø to rrr f,ô hs tho lc¡soh: vrrosc rbr.cs å¡peuu.d i:¡ro to thp forc¡¡oín¿ lnslruno:"!. ¡rrl ¿ckno¡lìd¡e l.lrrt. l4¡r for tlo prrrlìoso snd cotsl{torftion llu I lu¡ o t\er+in thoSr +r¡;r.!â}:(r¿, I öoì|nr:y, fgx¿s. AU HPPC 03089 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 179 EXHIBIT 7 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 180 l{.F. Iìoyd, SôcrêÈary, üsrîe to ordor affer ruorni.ng sereics at, liigh]"and Park tc l"lear rnport cf Nonr:inaÈing toümåùtee for cddåtignåI glders anci Ðcâoa¡rso fonr T, tarpoufcr ¡novesì th¿tt ättion *f tongregation at' prevloers meeting elecb ç:ix t'o and ùhat Pe be reseindetl, P 8l"de::.q an¡l fi're Ð*aeons be eiecled , of t'he üonuui.t boe ë;tüh* thls molLçn *as secande{i ancl r¡nanÈ¡n+uxly canried. was bhon ro*d, the fol.)-orrinü, nänsil beång subn:itted¡ For Xllders: Seç" ,1. lru¡ntldl T,P" Jur¡kj.n þeacoßs i.fÌ. M.J. ''Jntt t ¡ Sanctusiçp S "ftlsqn l¡ I I Joe B. J"ï" trit¿ Jn+u 11. tarpeni,er ïfor , ff.Ïr" Isganr Jr. Yi.I{. ürr E .lT. Iilum on ïa$ unani"$ous ån $Ieet:1,n6 lire me¡¡ rçïroso nanes were read. Àleotì.ng thcn upsn dåi;'o¡ 9lre neeíing m*s ci¡.I'lad bo <¡rder -flûr- the puE:rcae uf mget^ ti¡o regu3l*r a'b ê}ÕT¡ l¡e*rì had rqixåch budge| a.nx¡¿iï 0hu¡ch thç was )Íoderaior fln'å il .F.Bayd, Secretary" ingu February ?Nh Å to thø congrirgation, aad upon notion¡ dul.y' secondudrxa* the {sisned) l{.}'. Boyd¡ socretary ffillijTfi$ 0r' ücNßl$ìi]AïI0lIÂ.L MSAtING $undxy, Mt:rch ll-tbr I92B this rpeeiai nee|ing of tl.re Cang:.eg*fio¡¡ of tlS.ghtan<1 Park Fresbyteri"an thu:'ch of ìlni'ver,rity Fark, texas, nax irelc! ai ttle usual pÍ";rce of aorship¡ on cal-l ix¡ql nabJ'ur¡:ncrde zurû giïen in'com¡rlia:rre rittr ùhe Hook *f ffiurch þrcl*r of the Presbyterfan Chu¡:ch:Ìn the tr¡ilud $t*Þus cn thia lltir llarchr å!?fi- Meeüing ea^-ï cål,led. to order by Rrrv ìf.4. aeterl *n $ecrçNary thereof. 'l}¡o foSlowing. îësÐÀì^exarider, rai;or, ancl I{-F r wl¡o r¿ovû<1 ito adoplicn, nnd aftpr conside::¿"bioR lution rrss red by Joe E. tio:r x*s *eeon<T.ed, subnitted to a vota, and carried a.:rd <li,sr¡rss iho lt$tio¡ fs preeentt aLl rcøtnbere afl"ånnålicn vcte of by tire \lheregs, the tongregaÈfon al Highlan<i Park Fresbyùer:ian¡ tit*rr;h of Universl.ty Farkt ¡ lex;re, more partleula¡ly' Tex¿s, åow o¡nra ¿nd. holde a le--l of grcruid i.n ûattas li¡e of i,lnivereåty Eoul-eSeet the or¡ hundred úeucr1bed as fronting four {}¡r:C¡) v*rd 1g-ibh å ctÊ.pbi¡ s$üfhîflarrl};v bcNwren par,nllet l.ines üJ thrca hundred and eeventy ui,g¡t {:tS) feät along the eãsf line r¡f $hanr¡on Lane ån ErivaraiÙy Park, an wl¡åtb sê of conclucting gr6'.md the Church p.oposes t,r: erecÈ a ühurch buålrtfng for ths es of W-Ì,å. lïΡit*t¡* puÌ:1ia wu:rslrip ti:oia1n, the fible tc shåch 6reir.xrd is $*w i.¡r b tìre publåc neccnde ïon, .1, Couf6cu, ,I,trf, ü+rpenter, få.ìl.iJavio, ancl 11.Þ'. Soycl¡ , l I "l HPPC 03238 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 181 of aald öouniy* f,or lhe benefit of th:is Congregabion, anii Whrraas bo vnahle the øvectlon af such Çl¡urcìr bwi}åI.ng, åt Ís deemeci necesee:y to sccurç a J,.aa* o,t) m*n*y n*L to excs*d seventy-five tl:ousand doJ"Ï,ars($?trOûfJ) ln a* ;no-':nt l* pa;v * ¡:arl' of thc co*t af sueh thur*h çuí1dj¡e e^nd io å6eure the rupxy* ;ner:t oS r¡uçþ lq:ftl i:y a firsi ræ¿ul*eslaTe morbgag* rleed of lrust a$ $åI t'he Send and f.mpruvemsnte, furnftirx'e , fixburesp a*r.i equipmenì; l|¡ereln owr:ed, ar thaL nay hersa.flfle:: i:e acq*irod by this; an*l lTh*rean, arr¿irrgêBsrrt$ r¿'ere uade for sucl¡ lna¡: by authonity of thi^a tongr*geti.on given to jt's t'hen exj.et,Í-ng an<i auèh*:'ieeei By:ilcLirr6 tqruri^t,bue¡ ûd¡d "i{nare;rsr:t, ¡¡c¡s }¿rÈer'<iocltlcd t,*: i.n**rporat* th¿ Church organåratÍorr ê& å ror}ùrå* ðåcn rinder t"he si;.atuùes *"f lexas to àake.tj.èt* tCI aI) lb prop*rty ¿rnrl ía enable suck coxpcration tc bprrcx the aloresaid mor:oy nnd to tnûr'Lg{:gr}'Lhe Chuxchts aaid f}rûpðr1;y bn EecÌlr(ì payurent çf the }*an ¡ ì,hnr, Nhorefore, b* j"L by lhís meeiingt Iiøsolved that W"þ{" }lhåàenton, J.?. Coulsou¡ .T.fI. tarpenàer, il,tì,ir*vis, ¿":ld H"}".I}ayd çÍ¡* nov hoï"d the re¡:ord titie to the herel-nbefsre doacrj.bed proporly lre, anrl they irre hereby', au|horÍxecl, rer¡ue*ted and elirected ?o grant, eelp ar:d cónyêy a1l Nhe afors* said lclf of grorurd ¿lc i¡$ld by {.hen bo High}and Park Prewffieriar: t}iurch, ¿ Î'exss ccrporation, çi¡artared on BLh fuy of îr:bru*rXr, J92gr;rnd la drr)3r reeord ll¡eir deed so conveyibg *afr$ prcporfiy ån the offi.ce of the ûlcrk pf the üorrnty Cpurt of, ÐaLlxs, fexac, an<l be it furlher Ileuolvtld, that, Lire $oixrrl oJl Trust'ees or Diyectors or'said Higblånd Park Fresi4rt*rnian ühurch ber ünd they lreraby aro, aul'lrortzed¡ requesàed nnd rlj"r*r:tad to borrmy nat ts exceed seventy-fi'¿e bhor¡e,íìnd cloÏlars(&ffrffiI from Leçis 11, Tho¡usor¡ & öc,r Tnc, ûn tþ¡e te¡ur a.f, a eeriaÌ^:r prapcsal" d*ted I'lav*url-.er L2þ 1927, ¿c{<iressed ta lÁr, W"M. ifrit* i,enlonr feai^ra*rr, BulÏdtr.lg Couniflee *f Ïiightand Fark Pres@erfan ühurchl llnfuorsiby F"rrk, Texnn an<i *i¡ryed by Lerrlx W" l!¡onuon &. Ar¡., Tnc, hy t*Ni.s !1, Thonsçn, aird &cuep* l,ed by lhii).riing towr-1Èbee of lllglriand Park Fnesbyterian Church, by W.X. l{,hitenûcn, Clreirmarr, ìchitfu puapcaall ås herayr".iih presenLed Lc"bhia ne*ting íor its exêmi*ation, infor¡¡:atÍorr* considaratJ.sin and aefion, er:tl Ìrs J"t further EeBolvad Lhat *^11 ntepc íhat h*ve been ù¿ken by the a"1'uyes¡¡:!cl Buiid:íng tomrirj"ttea and a4y a,rtd all clh*.:r a'-r'Lhorløe¿l rëprÊser¡t¿tiyss u.f Lhis ûhurrh ån con¡:sction w:ith eueh hor:'awirig cf m*nøy, the l"etLing *f coriùracù, and ersstfçn t¡f said thurch bujådingo. an<J. the holdl*g and pledgÍ:rg r:f uai* property to securû the pa¡rcs¡t qf FÀ:ch lran be, zutC the síüÍe rÀre Lroreby, approverì, ratlfåcd anci sonfku*d, and be j.i Jlarèher lìerr:J"ved, ti:at tl¡o Soartl sf Tr'¡¡stees or llir$clors of eaid High}and llerk Fresbyterian üÌhurch, a corpara|ion, be and they hereþ å"re, euth$riaørtre requ€eèed, snd dlrectaçi to *atry ou.f, lhe h*reir¡be.flore ¡nenbionocl propaeaL for a ]oan f,ro¡o lg¡¡ig ff. lhorns*n &. Co., trnc,, with gach nociifi*s.fior¡ of the i¡¡aorr'¡t of llis l"aan, êTFÊJI$ê$ of obtalnin6 fù, ti-rue imd terqe of repayment, and covena:lt::, teãrnân collEi-it,ions , ffiå characte:- of llhe mortgage tleeci of t¿'*.sL or¡ lhe ¿r"f*reçaårl properly is secure the eane, ae in tlie opinåoll of s;r:ici *o¿rci of 'Íruetees or Ðirpctor* mey aêen nqcrss&i:r, convenåent a¡ el,esånable f,or it tr: rriake, and when inla Þy an<l Nhror:gh its officers in thro name and on 'neh¡i"f uf Highl¿*rd. Fark Presbylsrian Çhi:rch, a corp*ri*t1,cnu {slgned) !{.I" Ðcy*, $ec:'ot,ary HPPC 03239 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 182 EXHIBIT 8 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 183 ûz¡ rilt{ I uf s¡I ñÙc¡ÉÞ f.iilpÎ? ¡r:¡ ¿ç¡ lc/tf..c {$ó31-rÞl ootìô¡rir öðiðrl l¡ry lg, lç¿7 .n¿ bâr:lE¿ il¡ÉÌc,i 'rtntr dttè ¿t 'rht rott ct :1t pot ctnîu¡ ÊsrßIlÛ{u, a¡}d ¿üi Ê0ô peyrbto 1ú ¡èrthly ruG lD3lsllãcRlt {rÍ $l0"CC 6ËCb; St!t.?c ôj ÞcTôBca tðv¡ng, ba(ö Dàld Þrr råld tote tbero ¡ê¡41üð a ¿AC.ÛCi $¿rd f,(lô båitrg âccu¡td by yän0or'r llpÉ t?tåtsad in : el e!$l ilsts thcr¿rlçb ¡r(Ê åùbüt LÌ.þ!6 & ôorut¿8y ta D'tåck 8u¿åon sn.J b9 Dåod Öf Íllrôt åi3ú si eyên dûtê lh?¡oRrth no st¡lôrt R'ir¡rhs, lrurttç, upÒn LÍf ?rilTt 0ltB l¿11 1l vt¡t o: Û¡Ll¡s. ÍËrê.' ÊcÈordlã¡l ñLùCÍ FlFîÉÊf ltSl of ttKEÁãD lËqñÀflr 8¡ ¡äilltloo to tb¿ tô Chs tlct rhürrìof rcúürû€d tù tøl. 4. 9¡r߀ g?' UtÞ Bôcôftil.DÊLl'osCo[ìly' Tsri€¡ tùl i èô furl¡or ôrånt, 3c1l std C unÍoy ur'tt ihe îq¡d ito!ìttt?,ì, ilolÀti û11 thñ rlthte¡ il¿}år 'lBlnrsat,rÍrì ì1å, ot!¡til il¡ håld by lìi€ ¡n sÉld ÀohÉ hy ortg¡¡ ,rf r\ld !.ìt. hâr*¡n c)tY*9ûô md t96t6¡êt. it, ä,r,'¡I ¡lgþ I$ ll0J.lì úDtâ ü1,ê rÞld ffrlrx.Rf â. llotlL{rhta ùài¡9 otrd ùsglgn¡. ¿tr¡ 8i¡oer ôË5c¡rhad [êtó' to8cthlt tltù ¡¡L rad tinr.ülÀT tl¿ ¡bovt ¡anÈ¡úñ¿(i lter¡! rtr¿ út oui all tlmt, tløbtr" rqûlltüÉ, rotr¡dls' ?rlvltoßar, tlltùs aud !r aÊd rr ocld 1.c¿ô, rllût¡ I h¿r¡r bÍ vlrùurr sf hotrr€ !ùé 1ô6ef bo¡àés oti! oftor of !åJd ut tTf&ì¡l¡\ r.¡nHrNlt,nþ ihÀf ê11 pôJæDto' orcdltt o[¿ êffùcii to rblch ctld Éþia 1Ù oñlîr]od ,t!¡êrF rÀâtâ6ï, óll rlihou¡{äèÒu.å. or Ër hdevlt. TISUTEC lhl, th. l:Stô dåt öl l;oçéåbs: t'0. 1Ê3¿. l1Ð11F1 L. l¡0{i5 ('í. ttf rft -s1'År'J ðlrtìfrFì ldt. lìo tDcàrâl¿nç¿r â llìrtoly ¡ul'llc 1ü 0oó for clllllll vf ,/,u.¡Ü¡ It,c litslc ån( öüUtt á¡'otsäúld, on Èh19 dny toråonslly ôpÞ6u¡èC ¡l' 1". ilG'Jb tmn !o Belo bâ thf ?er30) çllcËå lam 1å suhs4rlÞt¿ ÈÙ ÈhÊ ¡'st*5è1¡ì6 lrt¡Iu¡At¡ àn¿ aokoontÞ'gld la nâ l¡o er#r¡i.î¿l lhe ieilo l¿ r ühå prrpoÉâs ûïüaon !l dtrôtlon Lhoro¡D Gt(pr?¡tad. 0lvflr ilnd0¡ [,t Hâld ùnd soel of off lcú rTt:lå thâ ,?SËd d¡I (!f Io!öùåi" 1àS?. 8- Í.ùvÞo,rD lÐs$ !lo:.t¡lìy pUt¡,:C ÍûF fl t,ËD Poft ;læ3!rtr floY ¿ç 3Y C, \ ¡? 1l$0 p.H,-À.n. 19S¿' t.8.FT$!ffi UÁLLÂ3 COVh'[f ' 3EfÀ8' COINIT DL!Hr' C. 3grm DæFr.r' RSC¡|¡ÐED Dã: 15. l?fz. J åÞrql?R c4¡rNTY ;LEllti t ng'|r tlv ltrtiitiÌll ê;is7t....,.", î.¡1, v::IîRJltN sT.qlÉ OF 1&/t5 rr ¡,i :TÞiΡgiÉ ¡û ÐEED ¡.lltlt:Æ¡9 rt¡{ I tÊEÐTTErtIÂN 1 01{ü!lCH CotìlllÛ itf o¡L¡'¡{s rd4Elt6, by rtaolutloü d[!! litoDiâ¿ ù9 tb eGa8leõÛ11ûn $f lllçLlnuil Pâ^jt lrùÉbytr:1& Clu¡cþr äl ô iltolln:, hol4 oL thâ I'llb dÉJ of l:årcb' 1923' tùt uhu¡lr ì:î¿Þaslgnôd lruâtsêã t6Fþ dlrùrtËd t¡ c:ouçtt ànd ðëllvÔr to lÌ16ùiâEd D4tk Ptüsbgt{f13tr 4írporâ¡lon, ó ûâêó ctmuylù¿i Ê ?srag !¡¡Ó ùÚrll(àfðË! dâSC¡)beC !8t¿ ail F;êilller :o Þ" 361ð åri!!rñl1oD. ì rsî, gfj¡ñi¿F.iit.8, Jrlto...' ,lLL lel 3Y Ti{ß,liu l':lfsãlr$: 'l$åt ìf'x'¡hltÛtloa' ¡l'!l' ñl6hlånó PsrÌ ;treåbytëÌ1êo sht¡t:ho¡otitr€ bf iuc tl:pu6h ltr ftlastËèt' rt)id, .tr? ,orulr)ä. J*6' Cæ|eiltôr ôYld H.ß,DÊrts, rf ¡t'ot$$nE!í ôl Dttlss' trl tb3 S-"å¿e tf I hà9 Cre tlt ôò' 9ol¿ Éod Cg)tctÞ '!a¡Áir I ñ ¡Érordflês rilh ûn¿ 1o çìlá,âldroc tJ tålil råÐlyttôr, A9 HPPC 03014 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 184 {ìl}l . ' úuó by lhÈro Þi6Ð3íLt ùoa3 iiÌlrir 5olt.roocÁrat uDtÒ tÌe rìàtâ Ërchtànd Ps):t !,rô3ttl6¡la¡ Ûl¡r¡'Jh' 4 Îôras Ircriìoretlún¡ (1f thê Cötory or DslIôs,3ù¿Ìê âf IêI0¿r rll ÈbBt êortolx ìeÉl s3ù¿¡ie slruê'd¿ 1n tß? Collty ¿f ¡¡olLôâr åâ rts Strt¡ 91 1cÌôrD.lng tfåct l|rtùêr osô c.f Urlvôrrliy lort rnd 1*1,"5*U ÍrgrþyiärtËT lihuxoù i.!üots. âgcü:-dfr€ !ú iùö pttf tlrôrmf rêoolðeô tr!ô1. tr tâga Pep¡ ¡6S ()f 0tllà¡ 3ou¡?g, trfc¡, ñóx ÞÈrt¡culjtlt à6Èô.ribld ôs follor"e IDG)llñ¡tlc lD tùr l.,r!tlt 1,n? ol U¡lr¡lrfly tsotr¡.er.rd åt tis lntor!?etlor ¡l¿! ',ña ¿ait t¡!Þ {rt'Slaûilôä l.ôuêi iänbt Sóu?h ól(EÍ rlå ãð¡Ê llnô of Shhnon LôîÒ ftf4.â loût 1o â lolDt 1: iìê ìiotth Llnr cÎ Íobôftû glPeoi; Th€nai .Þ8t â:nrc tl¡â Ìl,ortà ¡ tls cf ;iob.ttr Stratt ûí tÞa i¡op IOO f 8¡sE¿'dt oôt tà û lál1t Jþ ùhü Fódt I !nr! of | 9tráÞt no! fficd! ?btncG îlcrih cl$rg tb tîort. lino of eàlò uBûeôt ltrðçt :{t1"6 læÌ tô r Þütnt åû thú Setlr l,l)o cf U!leotüi1,}, âoulorardl Thüðô lo¡t üIoD6 ¡!o or¡d iouth : tno u¡ lÌqrrrt.rtt tÕuIe vs¡ô ¿00 lûêt tÞ '"1'ù pl*o of Mlltllllê¡ têtà t¡â0t rrrTr!¿:nlÍg S.,l'tI6 âsrés ùr l.t¡dr n¡rô lrölîfi th tùa Jôhn iiGltrlck $1¡¡vût. 10 B¡vE (]lD'IO tJù¡.¡ tba ôlr9v! doÉêrllroô p¡dl.t6, LÞ (:dl!¡Or rf.fb å1I ond J.lÞgub!' tlr rtgttt {nd aÞpurt4¡rr¡oos ùl}afürá lü ¡ttrlrt tr6tÕnAln8' alto úhâ trr.i ltrÍ¡¡âbd t.rl Ès3btt¡rf¡û¿ 3bì¡.chr a îcf,us cD:trx¡låqlo¡¡ tt! st¡ót4ðutg ènd orsl¿tr¡ rorå"ÈJ.ûl1c tl,c L¿tl¡ rlÐt sf liû¡cir, f.D. llAÉ. ri¡¡;llAr ù ¡,ú¡ìß ptu¡ilrlTI¡lfi c'rìut¡cfl , ¡t,3, -r, T, DÀVtß Co\tl,g)N ¡1. t. ÛofÞ t.tr. il," ¡fllt?cu J.!, Ct¡PFrîls $lrJrjttGs, çr¡'.¡Í {ì¡' f¿r,$ ùf tåL1¡9r ir8t{J}lö l{F. tt}o urdârrlgnËd, è fioiory l"$bllo la åû.1 lÕ: Corn0y. tr¿r6, ffi thtr d|y ÞÒ1gê!åilt ûp?orredË.1¿" Hl¡fîøl,lfrl. ;i,P. Ûåffì. ¡.", CîliLtot, l.t" f;J'J¡PF{Tn ,rfÞ R.B. ):.?ls, Tru¡r!óåB îl ntôhtùnd FRk p¡êàþt{BÈlqü (ìhûrch, t krilE to [c Bc bo $,â 0Èt3o[g riu¡rc n*l¡ ârÉ eubscrltaô ta thû loEtgslùF i¿rË:Hont, ¿nd i sßt:Èøtlâdgâd io nô thèt thry artËuÌüö ltâ ,s. fsr thr ttoF¡þ!à6ond oÞößldsrolfoD tÈû¡ÒIû lylrroãß{fi, sriå tli lbt s"Ë3alty tbrr¡l¡ 3t3tod. i¡ftÉil lÏlDn ¡.1 flÂllD ,rliD a}ÂL t$ 3ftlct, ì.nlr rl dcy êf ColiNff Dt!lê! Xeröh. ¡,',Þ. l0Êå. I.3 F"Íi, üaeþ¡t $ei,ilìl alb¡,lc! Þ¡JÀ!.5 ccÂ,trfrr ?&Âs. lr¡Ltì Fofi ilÞcçiir Ííôv û9 ct I¡4ô Þ.I.- Â.Þ. tÞ38, ¡,À.rl¿8!af c{illlff ç¿&tK li y o" c. $utî¡t D¡iûnr 8æoirÞED D¡Þ 15, :93i. i.D.p¡sl4R sfijfry cl.ilìt: frY Þ-¡.-.* "7.4n rr¿$n;,''l.jgd,n I I 0ce?0....".,.,. til.ttflÀll5 P;tr{ I''lFsßyî¡Rllrif :tì ¡'L".¿r;!11o¡¡ Í CWBgB ! I l i i I Al0 HPPC 0301 5 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 185 EXHIBIT 9 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 186 UNMEr} STATES ÞTSTRICT COUR"T NORTHERN ÞTSTRIÇ]T OF TBX.A$ ÞALLAS ÐIVffiION Hf ßHL AN Ð P.âRK PTTTiSBYTBRI.AN $ üÍ|T.JRCH INt,, $ $ Ptaintiffl, $ $ Cryn ACTION NO, 3:l 3-CV']SÏ 3 $ 1?" $ ffRAÇß PRESBV:ISRY, INC., $ $ DefEìdant, $ I, Michael J. Vaughnn under penatty of pcrjtrry, decl&Ë as followe: l. My natne is Michael I, Valghn I arn ovEr twsüty-ütê (21) rrrind, nnd fully competent 1o rnske this Þeclilttioil" I pr+stlytrriall öhur¡h (U,S,A.) ("PCUSA") sincc Frashytcrian Church, Wncoo 'fsxrs. f I9t3, h¿ve,.becn yçsr.s af ar.gs, of routtd a Rrding Elder i¡l hevhrg bscn ordalned by lhe First mn thc immetli¿te Ftsl Moderstor of Ornce Ftecbyrery' a Fresbytc.ryof the IICUSA. Thc þIorlçrator of a Presbytaty is n rnembsr of thc body, chosem by the mcmbe6 tu repreu$tt, in ä porscnr the unity ofi tlæ body, which is iu ten*ían betrvecn individual conscrøtc¿ and mqjority opinio¡, In this rolen Fresb5rtery, gntherìngs of Terching Elrtsr mer¡tbêr$ I presided over meetingð of fhe nfl the Prosbytory and Ruling Eldø curumissionors elects¿Ì by all congregatìone wilhin the Presbytsty, and wÈs the one to*porsible rvilh for sccing t¡at fhr¡ meetings wan: orderly ond that the büsiness of the body was eontlucted efficiency ¿¡3ild f¿lrness in ascordanse with rhe Constitution of thç PCU$,{, or, wilh Robort's Rules of O¡der, responr*i6le consern$ Þtì(1l ÂR .As Mot{erator, to ürs Fresbytvry fr¡r {he I {trat was silent, ssrucd on t{te Pretbyl.ury Counsil, the hody inrplsnrentatíon *nd caordination qf lhe preebylery, including the pastorul TION ÛF if overÉiglrt of tbc prioríties and of congregationr, tcuchlrtg eldgr$' MICI{AÍjì, J. v¡tlfcl'fN * P,+CU t A1'l Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 187 nrinitlries, A* Modçr$c¡r, ít and rvns my privilegc to ¡nodcr¡ûr¡ åhe ordinatíon zurd inslallutioll Teaching Rlderii (Mirriste"r*) futfilling the Presbytery's rcle ss s{Tlr$råta bishop in rvhich Teachirrg hierar¿;hical slruçturë, individual congrcgatir:n. tefore *crving of in our Elders ars ordaiacd by a Presbytcry, not by m *r Mocleralor, I eewed aç Vice-Mçdçralar of tl¡ç Prcsbytory; as Moderator r¡f the lrrcsbyærynr .Adrninistr¿tive Corvrmiusion ç* froperty, u commissiøR crc.Bted for the Þurpôcc of carrying out the Frosbytery's r€sgÐnsihílítics under the Buuk of Order wifh regunl to FÌrlprrt)r of congregatior¡s: s,fld as a membêf mdfor'moderator of varíaus Prcnb¡ery çommittsss conçernqd with propury rnattms, polity and crdination s{¿ndards. t þ¿vø bsuu a r¡çtnber of o congrcguÍion of the PCUSA. or it* pretlec+s.tor *cnçminatíons, for uver 32 ).åìftr#. I currently Êeilrô ún thn :setsign af FÍrst Prcsb¡cr,ian fihr¡rch, IIC{JSA congregation in lasksonyilleo Taxas, whero I arn a nrcmbor, Th* f¿cts stalcd in thiiç Lleclqraliolr arc bnsed on my personal knowledge and are truc and uolîert, o* ootinforrrration and bclÀef whert índÈcs€*d. If cnlled 2, ns r rvitne*s, I would compcrcmly teffff fo cuch ftcts. Under PtUS*{'s Constitutio*, *[t]he larger parl of the clrnrclt, ür e reprËËe*(atian thereof, shall govorn thc *rnallsr." .Sßø Bx, I (tons'titutton of ths Presbyterian Church (t1,S..4.J, Fnrt l[- I]ook of Ordcr åt F-3.0203]. Ttre Presþtery in tlæ rcgional c¡nbodimcnt of tho Church ond ",responsible for the governmert o,f ths church thruughoul its disuict. . , ." Sët l¿ ûf G- 3.03û1. PüUS,$, hae l?3 regional Prcsb¡teriee, including Grncc Presbyory nhioh contsÌfin cøagr*gutions a{.ross $3 sçruÌltier in Trrurs, inctudírrg }tighland 165 P¿rk Pretbyterinm Churph {"tr{PPt"). 3, Ar a hict¡rruhísd churçlxr ôon$rÞgêtion¡ become r'âftîliatss" of the Presbyterir.n Clru¡çh (U.S..{,} it.s - do not ".ioifir" "a$sôcit¡tg wiÙh,'o Õr they ¡re created by PCUSA lhruugh prcsbytericg. *'A congrÊg:dtio* irr nh* Prosbylerian Chüssh {U.S,A.) cnn be orgÊniøed only hy Þ*f t.ÂR^'t lûH nrr Mtcft¡rut,J. VÀucur{ - Pr\tË I A12 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 188 tlre authr:rity tì-I,{}ä. of a ¡lresbytcry nnd shall functít¡u under the provisions of tbås Cotxtitution." Jd, å( {Jndef the Collstitr¡don} the,presbytery has responsibility for *hrgnnizing- receivinß, trrurgiug; dismi**iug, *nd rlissclviug congregutions in canrultafìan with their rnçilrbtrs." ,fes trl st û-3,03ü1. Thc Prusbytery is ¿lso renpolrsible fot orduínir'rg end disciplinÌng congregationnl lcatler*, r.vhq arc rcquired to abidc by thc thursl¡ constitution. 4, Whm, "(alt irs sclo diÉcrctior the pæshyøry ,.. elcclarc[s] lhelrr un org*nia*l r;{rüS$eg*tìffi ot"the pr*sbytery," the'?cngregntiou çhsll lhon proc+red to thè, elestion clf rulittg elders and, if they *o decide, deaco$s. 'lihe presbyrery shdl ptsBâr$î ËËáffiinðr crdain, nnd i¡¡rtrll lhese ncwly rilc$ted personr." $ca id. at ü-1.û201, llhe srdination r-'nr*'s in¿lude alïirming: *'V/ill you tre gov+mcd I¡v our chwch's polit¡ and will you ctrid* by itr diucipline?" /d; ¡ì W4.4tX.):1. tt is crnly r¡po$ ânswcrirrg that que*tion nffinnativdly ilrat fho 'laaching lifuler, Ruling Elder or Descün wilÌ bç ordained, qr instslled in oflice if tlraì'person h¡tu îrcen pruviously ot<lnirrcd, Í, All Te*ching tilden urd F.uliug Blders lt lha PCIJSA lafte the very sûrne solcrìvl vow r.r{rtn ordaiue.d, tbus every T*aohing Ëidcr ¡nd Rttling üldnr at }IPPC, nffirrned thnt t}rey woultl be govemcrl by thc PCUSÀ"* Constitution unrl wculd *bide try its discipline, d, l,ncel cougrcgstions in Tcxas, end in my other *tate in which it 'is pennitttd by civil law, tre dirÞcted a¡rd rnandatfil to ineopor¡te, ¡rrd :tlrc ¿srpo¡aligfl is "subjcct tCI the autlrorÈty of tho scssion End uilder thc pmvisions of ttru Ct¡$stit¡¡ticn of the Prwtl$erifln Cllureh ({,},S,4.}." ,l'es dr{ at G*S.0101.. PCU$A preshgcrie* ffiry '"assune origiualjtrisdi<;tion in atty situatiou Ín whích it dutsnnincs that a scssian canüox cxercisc its authority . . . . [Î]hc p-resbytery m*y conclude tlul a tession of *rrrl .tnûy appoint aar tlt:d.t-Å Ê,,tr ts N e f' MKlrt a cocgrcgation is unablc or unwilting ts manügc wi*cly its alÏhirs, aclnrinistrative c$m¡rìinsion with lhe flult powcr of the s€ssiún"" À hi r".T. ï"A !jG|ì t*t kl, at G' - l¡ÀüE 3 A13 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 189 3"fn$n. T'ìris is $* rrxtraonlintry procedure under which fhe existing ssssioÉ csû$os ln function, a¡rd lhe attrn¡inÍdtr'¡rtive commís$ion *cls m thø Sc**ion, with all åütho$ty of th; Sessi*n, aud subject to the flhwch'r Constitution. llowcver* it is s.oÍilasn for administtati\os commis$iose to be *ppoiìted tô cxcrcicc ronti¡ro functisTrs on behatrf of the Prssbytory, incluúing recciviug Tcaching Elders, olread,v ordnÍned, wha rrc transfvrríng inlo Ërace Fre$ytcty fronr ¡nother Presbytøy aud octing with .r,cgard to cqngpsüetional rcquesti$ to selt, morlgags or loase real prúp€rry as re<¡uirecl by the lìçok of Order. Those actions qrç ntl repor{e¿} tü thë ftllÍ body uf Preebytery at thc nsxt rnestiftg. ?. Additionatly, the (Xtrch's Const{lution {Book of Or,der" PflÉ f}, Thu Rnlæ of Discipline) eont*iu* an elabcrNe schoms of 4pplying c.hutolr discipline in ærnedisl çtsøs or in disciplinory cases, within the s{Ìntcxl of pastoral cure afid Ðverslglìt, to pravent ¿nd correst ir:regulariticç and dclir:quencies pörso$$ (seø íd. st or ä persot¡ Il¿.ûIOt of councils and lbe prcvantioo *O correptío$ of o{.fonsas by snd F2.02û3* dofining ofJemc åfi åny act or o¡nission by a nrernber in an prdcred rninistry of lltc churuh that is contrtry to thc $cripturos at ths tonstitution of the PCI.i$A). 8" Ërom it* fonnation in 1f26 to ?odry, fliglrlanr$ Pork Prcsbyterian Churcb hs.ti hëen å eff$rôÈ{rfíon t"pt$ß'], of PCIJS,ô, or ítu produceosor cßtity, the kesb,ylerinn CXrurch Ín the Unfted Ståîö3 !ÍPPCI was created by the Frrsbytery by tralsfer sf rncmbers fbon¡ two existing PfltJS cnngregatinns, First Presbyterian Ch*rsh ün ùocernber ß, l9ä4, o:f 'Þallru nnd lgestmi**ter Fresbyterinu flhtrwlt. tlro Session of'First freebytcriu Church of Ðsllns ¡flirmed lh¿t'*tc¡ mssl the rorporrsifrility åtld opp$rtunity of Southsn Presbyterians in Þaltas and its envirulls,"' iï cxccuting an "expansion progrnm f,or the im¡nediate ft¡¡ure Þ[rú|"]tRA'ilüN ott MulrÅtit- J, VÁU6I{N rryns . . . t0 bc carricd out ¡s a - fA{Ttl4 A14 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 190 tielrorniuational elTort, ånd t] ûo be partícipatd in by all the Southcrn Pre$yteriun Churches in I)allas," iJx. 2 (i$essio.u Mirrutes cf First Frrsbyterian {lhurch of Ddlnc, lP2}-1p35, pp. 64-65}, 9" On Ðcceffiber 14, 1915, the Firrt Prcsbytcrian Ssssian appmvcd * resolution tç rqiss "ol¡f prmata lr:icJ of the $t0,0û0 approprinted to Prc.sbytcriur Chus:h txpansi*n in f)allas." ld rt 1f14" h¡ ddltion, a rusolutlon to s$k the.Ëxpansion board "to call a meetitrg to be held ån the þÎunícipal Bldg. of Flighland P¡rk qn $urrday, January 3, 19160 in thc irfìor¡oon, of ¡ll Fersons deriring to orgmiae herelry expressiug its heafly ¡ Southern Prwubytcrian thurçh irr *Iighl*nd Parlc the Cht¡tch qrppval of thc movement." Id. at 1rM, ên May 9' 192$' First Prresbylerian disrnisssrl 32 man¡bers to crcntc "Highland P** Freshyteríd,n Chrßh." HPPC was fomully sståblished Ín 1928 fcr '*thç nr¡intcnancc sf ths Frssbgarirur ühurch"" Ex. ? (Chartw). Ninetecn of itx r:l¡nrter ursnrba's $,ef,e transl-urs fi(}In Tveshnínster Prc.sbyterinn Chnrcl¡, which itccxf hnd lrceu¡ crtntc¿l fronr First Pr'csb1ßcr'ían church, D*ll*s' i* t*pr' lhil$$Ëh nclion otlltc Presbyføy" Thus, tr"LPFC csn trâce its origins dirsc{ly to two of the fìret Frerhyterirn chum}rcs in Dallss" t0. Ar *ll tÍfiles bsfü/een l92S and nntil reuríon in 1983, IIPPC wãs t co$stiluailt corgregatiorr of PCI".IS sufuject to its Constitution, ínclud*ng thu äook ofChu¡ch CInlsr. 11. In 1983, PCU$ reunited ivith the Unitcd Presbytarian f:hursh it¡ tbe Uniled Stetcü of ¡\rnerica ("UPCU$Â-'), thË f,onnæ "hor?heml'Fre*b¡erian -fhis r.eu:ioet \r'ä$ rrpprove<l dçnorninatìor;l to fcrm pCtlsÀ ¿Í the highe*t levcl.y of cach d¿'nominrtion. Àfrur a lengthy discerumen¿ proffi$s and consideration by vmjouc teneral Assemblict of beth thc Pf,tÊS nnd the UIICUSÂ, m ðgreëmüt! u¡'æ reachetl hetwoou tho two denominåfions providing that they wauld he reunire<l into u new dçno¡trinuior\ thÈ PCTJSÂ. ttollowi*g the comtítutio'*al procose of each dsûfimÍrutiun, the reunìon flgrsçmcnl we$ tpprored . rt $€(:ì'eR-òTtoN oy MÉnÀEË" L V^Lr(iHN n GenËral .\*sornbly for eaclt - P,ltE S A15 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 191 dürrontination, and unrler the tffïrs of lhe ðåt6ênìÊnq reimion bocanro effeotive on Jun6 10, tgS3. Undor {h6 t{firñ of tho rermion, congregatior¡e }¡rrd an cight year pedod guvorucd hy the nsw PöUSA Constitr¡tisn, to cttin in whích to,sle*t to bÈ e v$ry lirritcd exenrption that only ¡ll+wod lha coügrcgätiorì 10 bc cxempt fnxn r¡l¡t¡rtni*g prior Fr*strytsry app:ovnl of ccrtait Frûpërtl' trnnsactionn (mlas, ffitr1ÉÊgel$) and somc leaser) urd in pËûFefiy and schisru nrlcs all uther r$ìspccts br gclvsrnati of thc prcdoccssor öôrìstitnliou, ór, by ä ôupor:$ðjorìty vote of thc congregu{ion, to teEvs lhs thurch ¿nd tnke the. lty thc {213rrJs) gnoptrty. t?- ün May ?, 1984, HPFC, hy .tignul writing io ths, Iit¿ted Cferk of Grnse Prmh¡,tcrY, affimrcd: Highland Psrk Precbytrri*n Church ir¡ ¡. duly cnlleú CÐNßRA$ATtflNAf ÌÌISHTING ficld on Sund*y, ,{pr,il 2$, 1984, did adopt ltre following rËsölülioü: <tocs vote to e)ßusr i{ighland Fûrk Prcsb¡erian Churclr, Ðallas, TX' trïorn holdir¡g åts Froperty in accordancc r¡,itlr thc PtluSA) Eaok of Mer- fr*8.OlJtÐ. untl to clairn the eilcfpficr! ofÏered in ö-8,û?tÐ, which would cont¡üue tire holdhlg of property of HigNand Pnrk Church in ¡*cordsncç udith the PCLÍS Bcsk of Churuh Order (11182-83 editiou), n"fhç þ'onn of Govcmnrent, Chapttr Vl" Thc Congragrtion The Pterbytery of firace fu heteby infanmed of such åotion, and ix furtber infonned rh¡t th€ songrcßrl¡on of trIlghlud P¡rk Prtsbytorlnn Churcb, froln thn dntr of thit congregrtíonrl mÊüün& 'hhrll hold titlo to Ítr propcrty ¡nd cxc¡cls* ils prh'll*gru of lneurporctiou ond prcpGrty orvnershlpt' rccording io thc provfrionr of Cbrpter YI of thr Sook of Church Ordsr of ths Prerb¡trrtrru Cburch ln fl¡e Ualtcd St¡ter *r that chrptßr stlstcd on the d¡to ofJune 10, l9&3" Tlrurk you fur seeing thÈ{ Prssbytery teke* noteå of tt¡i* ct¡nstituti+nal action. ÞÊcl¡x*no¡l ûF M¡ttt¡rsl J, ViruûnN - FÀ01' 6 AIG Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 192 Hx- C {Ms), ?, 1984 tiPPC t¡;ltor} (emphnsi* adelal}, T'[rís lçtter ttas eignuú by Flørry Hassoll, Vice"Mq&)r¿¡tor of tlrc Se$s¡on of ltFPÇ, a*tl scçraratrly attcstøi lo by sigtlaturs of the Modsret6r *f the flougnegffinunl Meeting 13. urrql cxcrcisc tlll ùhnptcr and the CTcrk of thn fio*gregational tvleeting. frl. l;[PPÇ's siEncd rvriting rcuffifficd itt privilsges of incorçor.rtíon VI r¡:f thr-r Buok ol'Cbu,rcl¡ thtt chaptcr cxístr¡l Õn thc d¡rts il¡ comrniil¡rent "to hnld fítltJ to its propetty and propsrty arvnorchip accoxli:lg tç lhe provlsiotls Oslcr uf the Presby{erinn Church i¡l the llnife<I Stafes cf f nne !û, 1983," the dðte ol'thn rounion. us /d. (haptcr VI of tËrc tieûk of ilhurch {)rder" et thc tilne of ths puniono co$tai¡lcd lhu follorvhtg provisione rcganling $rrOprrty: (i"2 lf * putiuular church i* iaotrporatutl, the ptorrì*k>nr of its cluner and [:yturv* in accord wilh the Ct¡n*lituti*n of th+ Fresbyterían Church irl lhE lJnitetl.$tatcs' . Thc officcrs of the cor¡ror*tion mny be given rny Òr all of lhç ftllorring r:enpcnsitrilities: lroldírrg tillo to ohurch prelpr,r{y tor th* Frçnefit nf th¿ fi)rporrtliùü *ntl. tltc Presbyterian Llhr¡nclr in thc tJnited Stat¡:s, ô mrusf he {¡-} Jlll property held by or ftir a p*rticut*r church. whcthe.r logal titlc ìs ledged ìn a corpcr*Èíon, u [fB8¡es or truritçcs, or a*r m¡il:c.¡rporated associalion, il¡çl whol.hsr t!r$ Fro¡,öny is uscd irr prograrrrs of tha ¡rnr"ticulrtt ehuroh or rotainsd for the prodtrction of u\ TreìrJ in tn¡s¡ n€verth,ëlË$$ for the use snd bertefït ol'lhc Presb¡terian thurelr in Unitcd Stsles, income, is tl¡È S-4 f f a particular church i* <iiscûlved by the Prestrytery, âtleËtpl"l by rithcr nrrjority or ufianínlous voLo ûc tsithilraw ircnr thc ìlrerbgerian thutch in thc l}r¡iicd StatBs o¡ othewise ùçuåe$ l$ cxi$t ct furrutior rrt ¿r r¡ternhsr of'tlre Fresbyterinn Chru¿h i¡l tt¡¿ LirrÌte¿t ñraáes, any property tlmt it nr*.y h*vo sh¡il be wittrin lhe control af the Frer#ytety and nrny bc held for desìgnar*d puryosc* or sold $r dí$p$Èsd of in suçh ¡ft¡¡tlner uc ths Presb¡*ery, i¡r its dìrcretion, may direcl. $ Church in tho Llnited States ul'a paRiøular rhurch can be ;ievered onty by conrtituåÍo¡rnl action on tl¡s pn* of tlru Frcstrytery (a-1)' !f ihere is a sc.hisnr within the nrsrulrcrsfrip of a particutar ohurch and lhs Ftesbytety is unablc to efftct a rccouclliatisn or a dìvisinn into scparat¿ cÌ$rches withitl the Freshytcriali Cburch in the Unitcd SLÈtes {s¿e lö-?}, ttre Presbytety sh;¡ll deten¡tine if ane o!ìtire f:¡ctions ie sntifled lo Íhe ptopsrt¡,bntatmc it Ìs identíñed by thc PrcsbyÈery 8,s llrc tnrc ci¡urch within the Pre.sb;-tuia¡r ühutch irr tire Lhritcd St¿rtes. 1l'hie dotrcrnrination eloes rroÈ tle¡rentì uporr wluclr {aetion receivscl tlte majcrity vote.within the p*rlicula¡r c}rurch at the ti¡xr of tìle scftism. $ S-5 'I'hs rslntìùn*hip tç the P¡o*bßerian f)¡i.t:t,q RÅn$u o r Mnr r¡r ¡¡¡- f , VÅuttÍi¡ - li Àç¡ E ? A17 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 193 Iliis Chupler is <loclaratory of principles to whielr fhe Presby{erinu Ühurci¡ in thc t-tnited 9tates antl its Ðtecsdsnt church bodíes havc adhercd frorn the inccplion of the Freebyeriau form of chu¡rh govrÍnmrnt, $ 6-10 t;x. 5 (Ilook of Church Order). 14. I'hs PüUSA Canstitution, in its tsuok of, ürdor, contains nearìy idonticnl pr*visirrns, incittdiu g; G-4.02û1 proporty as a Tnol for Miltsiou fire property of tl¡a ke,sbytericn Chrrch il-f.S.A), of itg counríls ûnrt sntities, ûrid af it* c*lngrcgmÍon$, i* a tool firr thc arxornplislmnnt of the rnission of .Fesus Christ. in the rvorld. û-4.CI202 Decisis¡¡* Concurning Prspeüy Ihe prouisions of this Cons¿ítution prsscribing the m&Hrur in which decisìons are mtde, revírrvcd, ond corrscted within this ohurch are op¡licable to all m¡ttsra portaining t* propÐrty. ín'l'rust ,i Froperty.lfeld Ali prcporty hetrd by or for r ç$ngtegûtion, û Freâbytefy. å synod, lhe ûoneral rtssembly, or the Presbyterian Church (IJ.5-4,), rvhether tcgal title is lodged Ín a corpolatión, a tnlstrc rr truËröçs. or an unincorporutetl ¿ssocittion, *Rel wltelhor Íhe propcrty is used in pr(¡gÍüiltìs of a congregnlíon ar cf * higher cour¡sil or rqtained for thc pruduution ol income, ft held ifi tn¡st rßrrerth+'less for the use and bencfit cf tiro Presbyterim Chutth {rJ.s.À.)" fr-4,{12,\}3 Chursh O-4"0?04 Properfy Usod Contrnry to lhe Constit*tion tfflttuevet prtrpertf o( or held for, ¿¡ côngrÈgåtion of Ëhe hcsbytcritrt Churcl¡ (U,S..d.) çer$es tç b* u*eçl by thnt congrogatiou ss q congrcga{iul uf the Prrsbytori*n Llhurch {u,S.A") i¡r sccordance wi{h this Constitution, suoh pr$pfity ohsl} bc ?rel*, uætl, npplie.d' transfcrrcd, or *oki rs provided hy thc prosbytwy. ü-4"0â05 Fropaily ofla Digçolvccl or Extinct Çongrogetion Whcüevsr I congregålion is fonnully dissohcd hy the prcsb$t-ry, or h¿s becoÍnc exlirN't by raa*on of tho disperral of its ¡lromboß, thç absndon!¡¡$?t of itc worlq or othar çÈufiè, nuch property as it rnay havc rhall hs held, used, cnrl applictl for suslr uss$! pul'po$es, flltl hu$l$ a8 the præbytory mny dlrsct, Iin:åt, zurd appoint, or such property ftay þð sold çr *li*grosrd of as tl:e prcsbytery rnay di.rcct, in confclmity whh thc Consti.tution ufl t{re Frcsbyteriau Churclr (U,!l,^{.). ü-4^0?.û? Fmperty of toagrugatíon in $chisttr Tlrc relarionsir;p io the Frerbyterïan Clrurch {U.S A,} of a ccugregåfion can be *evere.d ouly by sonlstiÈutiónql soli$n on thè prut of flre ptcrbytety (G-3"0303b)' If therø i* n D!:(:I^AR^Tß)N ot¡ lvl¡c¡¡¡¡re¡" J. Vluc¡t¡t - Pnra¡; I Ar8 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 194 * schisnr within the mcmhership of cûrgrssntion ånd thË presbytøy is un;tble ln effêdt ¡ rcccncili¡rtimr or a divi*ior intc scparate congregations wiÈhin the Prasbyhriu Ë1¡urch (U,S"Á..}: the presbyter¡. shrll deturmÍrc if ons of the faatious i¡ entitled to lhe pruperty becsuse it is iclcntificd by thc prcsbyte¡:y as tlre true shurch wi.thin thll Presbytarian Chwah {LI.S.A"}. 'ÍTris tleterrnination doe¡ not depend upon which fncüion roccivcd the mqiorÍry voto within th* cangroga{ion ú th* timc sf thç schism. Hx. 1" 15. Under the exception offe¡pd in then 0-8.S7ffi (now 0*4.t208) that ITFPC ettotc, congregations {ro bound by {ho FCUSA denomin¡tion's conelitution did not conlain Preub¡.tøian thurch in the Unitod "t property provisions uulsss sifüilar ptoviaion , " , prÌor to rhe reunion of S{ates and The tJnitr¿l åelerrticatr ths. Ttosb¡eriul Church in the Unitcd Stales of ¡morica to fomr ttre Prçsb)'tßri¿n Çhutch (U".S.,q,}." tho FÇUS did contcin n sfunílar* al¡nost the prcdecessør Hx,l, Íx fact, {he aonslitt¡tion of provisiun, *s quoted above. By choosing this eloctio ruPf'C reåflIrnrd åts agrccm.c.rnts undrr both the PCU$ ffid PCUSA's trì¡st and sehism pro"-isions. Once madc, the eleotion is permanenl ard c¡r¡nor bímodifiecf. l.Indcr ç*{.0208, coogrcgntíons elsctirrg thc exsnrptiou "çhatl hold title" utdor the PÜüS nrløs uud fitn*sx@fi]pl. prouisione "shnil apply to all ccngrcg$ipns of the Presbytarian Chur'ch (tJ-S,Å.)." LÏnder the # Û- (.Ìonstitution, '{tJlro puvisioru cf û,{.0208 of thís Cor¡stilution shall not bc ilmeßdflL" fd, 6.0s. lú" thcological Thnss rufcs regarding schiem r¡lld tbc dispu*ition o.f thurch prqperty are deeply ñútem. ?tre Coustitution r¡f rtrs ÞCUSA pmvides "rvheFÉvcr {hcy thåt pfffieulär ocngregÈliollsr arr. taken cottcctively colrsÈitule one church," /¡t at F-}.0202, "Ihey $:e ul} integral pnfis of the +hurch and camprirc lhp w{ro}e. Their govcrrrmce Ìs scr forlh in thc flun*titulicn, md their propét1y *nd ilr use arrd ownemhip cannû1 bo separated from the nrganizntlon rnd govnnronce of the shürsh as a whols. Thir strong ôrgnr¡ic'unity of goxenrrnsnt, cxprussøl in u gradod series of govomiug bodiaa, has bcu¡ haditionnlly onc of tlre ifi$inguishing Drl;r*nr{'f'tùN t¡¡' Mr¡ln¡;l J. V¿utittv - Prrcil,, S 419 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 195 I i ! i a 1 r traits çf thç church and is faundsd rrpen ä deep cornrrritrnsnt tc Rcfqrriled principlm of tlrerlogy t ffirl þ$lity. Tliese púnciplæ are enrbodied in ths Constitution of tlre ïrresbyteriun Chwch {U.S.A.), lÏre pruperty ot'each particulur phurch must åhsri bs used and owne¡l in t rnurncr th$ is caln$ìsts¡tt with tlrum and that strengthens and exhitlitq the unity af thc drurch." Hx. $ (Mí*utas êf thë (ìeneral /ssørøål¡,, 1990, RequeËt 90-24" ON THß TtlvfB Of ïHÞ ES'l'i\BtIS}lMËN'f T}P: TIIE FRESÐYTBRIAN TH$RCÏ{ (U,s.A.) ïIffTþI RESITTSCT TOTHB EXCËTffTO}{ TN T" 8"07ül (.Mirutcr, 1990, Pårt I, B- 260) *21-24V. l7^ [n 1991, HPPC, upÊat $,bouf isoue¡ it disngrætl with FCUIïA on, ì*cluding FCUS.A'* sultport of the role of ì¡/otnnt Ín the Clurcþ Ètttrr¡p$¿d å vott to lceva ÞCUSA. HPPC'g së.Ëdon rcquented the Ptcsbytor¡, to coll â sonsrogetion¡l mec*ing üo voio to le¿v¿ thc PCUS,{ rvith its property. This vote hec$ms nn option whcn flre 1983 PIan for Reuniû.n was adoplcd anrl congregntionc u¡ishlng to leuve lvith their pfoperïy f,u¿ -lhe * 8-year rr¿indorr¡ to do so. sûnior pâstör, Dr. Qlaytron Bell, did not u,ånt to lcave the PÇUSå and the pre$bytsty estnblished ffi admiüis*å{ivc comn'¡isslon to work u,rith, HFPC in its discemment. On April 3, 1991, the Frerbytrr:y sont a lçttor to HPPC to ûddrcou coûc.onì$ overo lhe prûperty tlut tirs "Presbytoty may 'takc uf ïIighland ParT< Frcsbytwían Church if you do uof vots now lo leave denr¡min¡tiün"" Ths Fresbytcry \{,rcte: "If, tt goms füturre tlrs timo, a large mqjoúff otthe High}ûsd Patk ú'ongrega{ion elìould dçsiro to nu longor ba a part of tlru Presbyteríau Chut'ch (US.d) and wish to be di¡rnissed wÍth its pnopefty" nasst6, ¡nd tiabilitiæ in acc-ovdance ryiltrt the took {h'eler #-l L01.03i to ücther al Refarcn$d }ody, õrnco Presbytcry hns officiatly pledgpd to rrork with the Congrugntiou toward that cnd, nraking an c4uitable divigion bctween those seuking disrnirs¡l and thc minority." Êx. 6 (enrphasis rddod). ÞEct-r\RÅTgQN ùr Mrct{Aål, J, V¡ruc¡tN - pÁür l0 A20 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 196 t $. T'hr Prerbytury assisted in securìug a faciltty wftere several tltousa$d pwple uould bo prenent tû vöfû Çü th¡s #rûrtsr, and hirøl a* ínclepondønt fln'n to nranagt tho voting prossÊs, Thç l'ste uf the congrcgation did not m$ct ths rwÐ-thirds rÊqr¡irer$snl 1o ìe¿lvc rvith 1"$. Narv, $IPFfl rçishcs agnån Ëü(}; A Coven¡rnt {.}¡:der üu i¿s propeny, rul'isit the isst¡e of latvlng its dcnontififttior, to join of Evangelical Prerbyleriftrts {"HCO!'), a tlrfferent denonrintlion formed í* 2ù12. Untikc I;lltPC's previous vots. however, thås tïnre it hm not followc¡l the t)hurch's cor¡stitutiein*l pnrvisiuns arrd prt:ce<;lurcp l'ol tTe¡:nrting congn',galions, ftrsleå{. fivc lrustecli of thut congregation rctninecl c¿unsel tc obt¡rin a TR.0 that cu¡joins ilre ChurcÌ¡ from exaruising its inlcrnnl üonstitu0iorral plocetlurcs f,or congrcgatìons úut'rvish ts bc rlisrnisstd from tho Churclr, ?(). l-lnder the Coustitulitrn, Presbltcries t¡nve thc nrthority 1,0 prornulgtte pulicies ftn cangregations, truce Frasft¡ury promulgatetl u o'Just md Çmtious Ði#rissal Polict'' for co*gregati*ns seekirig to bc dismissed from tlrc Pr.esb¡(crian f,lhutct¡ (U,S.d,), I'h¡t policy rvos atlnplcti *t a $t¡txl Mecting of the Frestryfery by rnrjority voÌs, üf[er scnrpulowly hllowing prcl¡sr prrycedurer for aeloptlon of Frushytery p*licic*. Those proccttutos inülüded. presctrlation of'the policy af ü n¡Fetiüf4 trx a lîrst feadrng, thcn corrsider¡t[on at a sutrseqltent mc*tittg. Àmple opporlunity fpr smrntlmen$ and clrange.l lç ilrc propard policy wßre ¿flfordad, utong uith Nengthy clcbutc a pröce$$. In fact, Ð grouf, of iudivitlu¿¡ls, ìnclucling HPFC's theulogi*rn in re*i$*lrcø, ofïered a aubstitutc plnn. "¡\f?er eurridering tmth plans, Grace Prerb¡(ery apprtrvetl thc ,Îq¡st arrd firsçiouå Disrniffial Poticy, and it became etlætÍroc upon rdoption.  con¡gegnfi0rt witlrin tlrc jutÌsctictio¡¡r¡l bnunrJs cf ümce Preshytcry i* obligated to follor+: the procodures outlin¡xl in tlrc *Jusf o¡rd Graciol¡s $isnri*sal Potiot'' in onlor to ohtain di*rnis¡al from tlp Ilrnxbytøri an Çhnrch (U. S.Â, ). fj}ì¿'lålt,\ lröN of MIL'IlAh:L l. v'\uütl¡í,* ¡rÀQli I I A.21 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 197 2l 'lihe Presb3'tcri¿a Churoh (tJ,S,Ä,.) ir a constitrutionttl, hiermCIhic*t church. lli'l'C was fr¡mrcd hy arrcl of tÌrot ühnrch, hns b*cn srtbject to irc Constitution for de*a$eun and rc¿rflin¡ecrl ì{s col¡ll¡ritc}Ìmt trJ üm Churcl¡'s proeudures for properry, schisill, antl disû¡isral i$ tq84. Ht)P#'s lurvsui{ fi{)rv rnis m thü l¡eari of r:ur constitutiannl structure md our right to goro!"û i$terüâl Churclr afllairs, Xä" Attaclred hereto as Sx, I is a fnlc md concct copy of ër(c€rf,lû ftctn Co¡tstiíution *f tho llt:eshyteri*n Church iLl.S.Â.), Part ll, 21, Mirrages ûøa.k of O¡:der" Á,tfecl¡ril hercÏn fi.c Lir" 2 is a lruc and rüaccl c+5ry ttf excËrils fmm $eñion of tir* }irst Prr;*hyterirnn (lhurch of Ðallns, lt?3-Ì935, 24. Atfachrtl lrercto å$ Iï¡" 3 is a true and cr¡rrr¡ct uopy ol'tha May S, 1984, lener frortt ïligh!ilnd l'ark Frcrbytqri¿n Chureh tr¡ the Stnt¿d Clerk of Çmse Itresbytery. 25, ¡\ttacheel her,et¿> *r hix. 4 is * tflte an(ì ëoftutt'copy of sxëÐrptl; fr,om lho Constit¡¡tion of the lrr*nbyteriur Church of the Llnitcd SÌutss" S<rck r¡fl Chur$h {)nler (lr,l82rÈß3j. 2$. Attanllctl heretu us Ex, 5 is u lruc and €(irÍcr.r copy of .4ss*nsh$,, ltì90" Rcr¡ue$t 9{,-?4. ,ly'im¡¡¡rrç u{ th* {ìrrøet^al Olt TIIP Tlîvl$ OF Tffß ËST.{BLIgI{lvlËNT' OF TI'lË JIRAS$YTHRIAN ü[liJnÇH (U.,-S.A,) Wt'rH KESFÉCT T0 T]tË EXCÌEFTIû,í lN G-8,$?01 qfutin*t*s, lllt]0, P$rt 37. T, p, 26{}) Attlchcd hereto as Bx, ó is a tn¡e and conect uopy of an April 3. Lc)91, lcÈtsr fro¡n Õl¿tçs Frcebytery to Higlrlarrd llnrk ltrcstry(erlnrr Churçh, 28. .{ttaçhrd ller*to ns lix" ? is n tnu¿ ærd Ëolrí{t çspy ùl'the l9?8 Çl¡art¿'r +f Èlighlancl Pnrk Frcsby¿etim Ç*hu¡¿h. Ï)tÌ(]¡:.¡rRÀ'f Kf¡J oÞ'.Sál{:l.t^tii.,f . VAU(tl,N - F*t;l; I I A22 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 198 I deolårÊ under pcnralty of M&*cf perjuy that ths forogoiqg is tue end oqrmoet, Executed this $iiptcmbe¡, z0 t 3, Ir{ichuul J" Vrugþ "1 DEc¡l,h¡\Trot\¡ or lelrcl.¡ÀÈt J, Våuôt*{ - P*m t3 423 Defendant's Affidavits in Support of First Amended Motion for Issuance of Letters Rogatory and Forthcoming Motion for Summary Judgment - Page 199
Similar documents
dven ecital Sere
The Park Cities are blessed with great organists, but they’re never in the same room at the same time, except for special performances like this. Virtuosic neighbors come together to perform on HPP...
More information