Steve Ellis - Ted Klein - Edward MacKenzie - 02-27-2015

1 The Massachusetts Association of the New Jerusalem (Swedenborgian) and George Chapin.

2 Thomas Kennedy; Boston Society of the New Jerusalem, Incorporated (Swedenborgian); and Bostonview Corporation.

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, Pemberton Square, Suite 2500, Boston, MA 021081750; (617) 557 1030; [email protected]

SJC09856

THE GENERAL CONVENTION OF THE NEW JERUSALEM IN THE UNITED STATES OF AMERICA, INC., & others 1 vs. EDWARD MacKENZIE & others. 2

Suffolk. September 5, 2007. October 15, 2007.

Present: Marshall, C.J., Greaney, Ireland, Spina, Cowin, & Cordy, JJ.

Practice, Civil, Complaint, Motion to dismiss. Religion. Jurisdiction, Ecclesiastical controversy. Contract, Construction of contract, Church. Conversion. Words, "Cease to exist."

Civil action commenced in the Superior Court Department on August 4, 2004.

Motions to dismiss were heard by Patrick F. Brady, J., and entry of judgment was ordered by Catherine A. White, J.

After review by the Appeals Court, the Supreme Judicial Court granted leave to obtain further appellate review.

Howard M. Cooper (Julie E. Green with him) for the defendants.

Lawrence R. Kulig (Damon P. Hart with him) for the plaintiffs.

COWIN, J. The defendant Boston Society of the New

2

3 The parenthetical "Swedenborgian" is part of the official name of the defendant Boston church as well as the plaintiff Massachusetts Association of the New Jerusalem.

Jerusalem, Incorporated (Swedenborgian) 3 (the church or the

Boston church), is a Swedenborgian church that disaffiliated from

(withdrew from membership in) the plaintiff General Convention of

the New Jerusalem in the United States of America, Inc. (the

General Convention or the national body), a national denomination

of congregational Swedenborgian churches. The national body

commenced a civil action in the Superior Court, seeking, among

other things, a judgment declaring that, under the Boston

church's bylaws, this disaffiliation triggered a transfer of the

Boston church's assets to the national body. In a related claim,

the national body asserted that, because the disaffiliation

caused ownership of the Boston church's assets to transfer to the

national body, the retention of these assets by individual

defendants Edward MacKenzie and Thomas Kennedy created a

conversion. A judge in the Superior Court granted the

defendants' motions to dismiss. The Appeals Court reversed the

judgment with regard to these issues, while affirming the rest of

the judgment. The Gen. Convention at the New Jerusalem in the

U.S., Inc. v. MacKenzie, 66 Mass. App. Ct. 836, 844 (2006). We

granted further appellate review limited to these issues, and now

affirm the dismissal of these counts for failure to state a claim

upon which relief can be granted.

1. Facts. We summarize the relevant facts as alleged in

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the amended complaint. Since its founding in 1818, the church

has been affiliated with the General Convention. Under the

leadership of MacKenzie and Kennedy, however, the church broke

away from the General Convention in 2003. Prior to its

disaffiliation, the church's bylaws contained numerous references

to the General Convention. The provision at the heart of this

litigation is entitled "Dissolution" and states:

"In the event that the religious body known as the Boston Society of the New Jerusalem, Inc. shall cease to exist, all funds and holdings shall be transferred to the General Convention of the New Jerusalem in the United States of America.

"These assets shall be held in escrow for the establishment of another General Convention of the New Jerusalem (Swedenborgian) Church within the City of Boston, Massachusetts. After a period of twenty (20) years, should no such Church exist, the capital and income therefrom shall revert to the General Convention of the New Jerusalem (Swedenborgian) with any restrictions of uses which may have been voted by the Society members at the time of the dissolution."

Since disaffiliation, the church has continued to function

under the corporate name of the Boston Society of the New

Jerusalem, Inc. (Swedenborgian). It retains the same pastor and

carries on many of the same church and charitable services as it

had prior to disaffiliation.

The plaintiffs filed an elevencount complaint in the

Superior Court. Count I sought a declaration that, by virtue of

the Boston church's organizational bylaws, at the time of its

disaffiliation from the General Convention, all of the Boston

church's assets reverted to the General Convention to be held in

trust for the establishment of another affiliated church. Count

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II alleged that the individual defendants wrongfully converted

the assets of the General Convention to their own use. A judge

in Superior Court allowed the defendants' motions to dismiss all

of the plaintiffs' claims. See Mass. R. Civ. P. 12 (b) (6), 365

Mass. 754 (1974). With respect to count I, the Superior Court

judge reasoned that the language of the dissolution bylaw was

unambiguous and did not apply to a disaffiliation from the

General Convention after which the church continued to exist.

The Superior Court judge also dismissed the plaintiffs' claims

for mismanagement and misappropriation of assets for lack of

standing, explaining that "[s]uch authority rests exclusively

with the attorney general."

The Appeals Court affirmed the judgments of dismissal except

in regard to counts I and II, ruling that these counts should

proceed. The Gen. Convention of the New Jerusalem in the U.S.,

Inc. v. MacKenzie, supra. The Appeals Court held that the

dissolution bylaw was ambiguous because "the term 'cease to

exist' is 'susceptible of more than one meaning and reasonably

intelligent persons would differ as to which meaning is the

proper one.'" Id. at 842, quoting County of Barnstable v.

American Fin. Corp., 51 Mass. App. Ct. 213, 215 (2001). Thus,

the bylaw could apply to both disaffiliation and dissolution.

The Appeals Court interpreted count II's conversion claim as

"premised on the proposition that MacKenzie and Kennedy

wrongfully converted assets of the General Convention for their

own use," id. at 843 n.10, and thus permitted that count to

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4 As the Appeals Court concluded, the First Amendment to the United States Constitution does not prohibit a civil court from exercising jurisdiction over property disputes involving a church so long as the court does not intrude upon issues of church doctrine, polity, discipline, and internal operation. See The Gen. Convention of the New Jerusalem in the U.S., Inc. v. MacKenzie, 66 Mass. App. Ct. 836, 839840 (2006), citing Callahan v. First Congregational Church, 441 Mass. 699, 708 (2004), and Jones v. Wolf, 443 U.S. 595, 602 (1979).

proceed as well.

We conclude that the dissolution bylaw was not triggered by

the disaffiliation because the plain text of the bylaw clearly

contemplated only dissolution of the entity itself. Since the

church remains the rightful owner of its assets, the plaintiffs'

conversion claim also fails.

2. Dissolution bylaw. In reviewing a motion to dismiss, we

accept as true all factual allegations in the complaint, and draw

all reasonable inferences in favor of the plaintiffs. Nader v.

Citron, 372 Mass. 96, 98 (1977). The complaint should not be

dismissed for failure to state a claim unless it appears beyond a

doubt that the plaintiffs can prove no set of facts which entitle

them to relief. Id.

The bylaws of a church corporation form a contract between

the church and its members, and are interpreted according to

principles of contract law. 4 See Mitchell v. Albanian Orthodox

Diocese in Am., Inc., 355 Mass. 278, 282 (1969); Kubilius v.

Hawes Unitarian Congregational Church, 322 Mass. 638, 644 (1948).

The words of a contract must be considered in the context of the

entire contract rather than in isolation. See Starr v. Fordham,

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420 Mass. 178, 190 (1995); Charles I. Hosmer, Inc. v.

Commonwealth, 302 Mass. 495, 501502 (1939). When the words of a

contract are clear, they must be construed in their usual and

ordinary sense, Ober v. National Cas. Co., 318 Mass. 27, 30

(1945), and we do not admit parol evidence to create an ambiguity

when the plain language is unambiguous, Panikowski v. Giroux, 272

Mass. 580, 583 (1930). In Robert Indus., Inc. v. Spence, 362

Mass. 751, 753754 (1973), we explained that extrinsic evidence

may be admitted when a contract is ambiguous on its face or as

applied to the subject matter. The initial ambiguity must exist,

however. Furthermore, extrinsic evidence cannot be used to

contradict or change the written terms, but only to remove or to

explain the existing uncertainty or ambiguity. Id.

With these legal principles in mind, we turn to the facts of

this case. The General Convention argues that the dissolution

bylaw is ambiguous, and could apply to a disaffiliation of the

church from the General Convention in addition to a dissolution

of the church. The thrust of the argument is that the words "the

religious body" could refer not only to "the Boston Society of

the New Jerusalem, Inc.," as explicitly stated in the text, but

also to "a religious body affiliated with the General

Convention." Although the latter phrase is not found in the

plain text of the dissolution bylaw, the General Convention

argues that it is a possible interpretation. Upon

disaffiliation, the "religious body affiliated with the General

Convention" would thus "cease to exist." Another way to put the

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5 General Laws c. 180, § 11A, provides as follows:

"A charitable corporation constituting a public charity . . . which desires to close its affairs may, by vote of a majority of its board of directors, authorize a petition for its dissolution to be filed in the supreme judicial court setting forth in substance the grounds of the application for dissolution and requesting the court to authorize the administration of its funds for such similar public charitable purposes as the court may determine. The provisions of this section shall constitute the sole method for the voluntary dissolution of any such charitable organization."

argument is that "cease to exist" is ambiguous, and could mean

both "to dissolve" and "to disaffiliate." See The Gen.

Convention of the New Jerusalem in the U.S., Inc. v. MacKenzie,

supra at 842.

We do not locate an ambiguity in the language of the

dissolution bylaw, and hold that it is triggered only upon

dissolution, and not by disaffiliation. Massachusetts mandates

that charities follow certain statutory procedures for

dissolution, see G. L. c. 180, § 11A, 5 and the church has taken

none of these steps. More importantly, it is undisputed that the

church continues to exist, and that it engages in religious and

charitable activities, much as it had done before disaffiliation.

Turning to the plain text of the bylaw, it is entitled

"Dissolution," and disaffiliation is mentioned nowhere in the

text. The text concerns only the "ceasing to exist" of "the

religious body known as the Boston Society of the New Jerusalem,

Inc." Our interpretation is supported by the final sentence of

the bylaw, which provides that the use of reverted church assets

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will be in accordance with "any restrictions of uses which may

have been voted by the [church] members at the time of

dissolution." To read disaffiliation into this text is to strain

the plain words more than contract law permits.

Plaintiffs argue that language stating that assets "shall be

held in escrow for the establishment of another General

Convention of the New Jerusalem (Swedenborgian) Church" renders

the term "religious body" ambiguous. We discern no ambiguity.

This language is consistent with dissolution. It may indicate

the close relationship between the church and the General

Convention at the time the church bylaws were drafted, but that

fact does not create ambiguity in an otherwise clear text.

Plaintiffs also argue that, if interpreted in the context of

certain other articles of the bylaws, the dissolution bylaw could

reasonably refer to disaffiliation. We disagree. Article III

refers to affiliation with the General Convention since 1818 and

the church's delegates' right to participate and vote at the

General Convention's meetings. Article IV refers to transfers of

membership to the church from other General Convention affiliated

churches. Article VI provides for the election of a new pastor

for the church, and requires that the new pastor be in good

standing with the General Convention. Similar to the dissolution

bylaw, these provisions also indicate the cooperative

relationship between the church and the General Convention at the

time of the drafting of the bylaws. They do not, however, create

an ambiguity that "ceasing to exist" was intended to mean

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"disaffiliation."

Other States have taken a position in accord with the one we

take today. For example, in Christensen v. Roumfort, 20 Ohio

App. 3d 107, 108 (1984), the Court of Appeals of Ohio considered

a provision stating that the United Presbyterian Church in the

United States of America (UPCUSA) would gain control of a local

church's property "[w]henever hereafter a particular church is

formally dissolved by the presbytery, or has become extinct by

reason of the dispersal of its members, the abandonment of its

work, or other cause . . . ." The court held that the church was

not extinct even though it had disaffiliated from UPCUSA. Id. at

110. In First Presbyterian Church v. United Presbyterian Church

in the United States, 62 N.Y.2d 110, 123, cert. denied, 469 U.S.

1037 (1984), the Court of Appeals of New York considered a UPCUSA

provision stating that whenever a local church is dissolved, its

property shall revert to UPCUSA. The court held that the local

church's disaffiliation from UPCUSA was not a dissolution or

extinction that would trigger this provision. See id. The

Supreme Court of Missouri reached the same conclusion as the

courts in Ohio and New York on nearly identical facts in

Presbytery of Elijah Parish Lovejoy v. Jaeggi, 682 S.W.2d 465,

474 (Mo. 1984). Those jurisdictions that have awarded property

from a local church to the parent church upon disaffiliation

generally have done so on the basis of different assumptions as

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6 See, e.g., Central Coast Baptist Ass'n v. First Baptist Church, 154 Cal. App. 4th 586, 592 (2007) (holding that disaffiliated church had de facto dissolved when last vote of its full membership was to dissolve and to transfer assets to mother church); Wisconsin Conference Bd. of Trustees of the United Methodist Church, Inc. v. Culver, 243 Wis. 2d 394, 407409 (2001) (holding that disaffiliated church had dissolved within meaning of State law when statute provided assets shall revert to Methodist denomination "[w]henever any local Methodist church or society shall become defunct or dissolved").

7 We thus do not consider allegations in the amended complaint and in the affidavit of John Perry regarding circumstances surrounding the drafting of the dissolution bylaw.

to the facts. 6 To the extent that the facts are not

distinguishable, we nevertheless decline to follow the reasoning

of these other courts.

Since the plain language of the dissolution bylaw is

unambiguous, we do not consider extrinsic evidence such as

allegations of what was intended when the dissolution bylaw was

drafted. 7 Plaintiffs argue that we are required, in reviewing

the motion to dismiss, to accept the General Convention's reading

of the dissolution bylaw in favor of the General Convention, as a

true factual allegation or reasonable inference. But the proper

interpretation of the bylaw is a matter of law, Berkowitz v.

President & Fellows of Harvard College, 58 Mass. App. Ct. 262,

270 (2003), and legal conclusions cast in the form of factual

allegation are not taken as true on a motion to dismiss, Schaer

v. Brandeis Univ., 432 Mass. 474, 477478 (2000).

3. Conversion. The plaintiffs' claim against the

individual defendants MacKenzie and Kennedy for conversion also

fails. Count II of the amended complaint alleged that (1) the

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assets of the church, as a result of the disaffiliation, were the

property of the General Convention; (2) the individual defendants

knew or should have known that they had no right to this

property; and (3) the individual defendants, nonetheless,

exercised acts of ownership and control over these assets for

their own personal gain.

The defendants' primary argument is that plaintiffs have no

standing to bring this claim, because the Attorney General has

exclusive jurisdiction, with narrow exceptions, over management

of charitable assets. Weaver v. Wood, 425 Mass. 270, 275277

(1997). We need not address the issue of standing here. The

conversion claim is premised on the fact that the General

Convention is the rightful owner of the church's assets. Since

we have rejected the General Convention's claim of ownership, the

conversion claim fails on substantive grounds.

Accordingly, we affirm the judgment of the Superior Court as

to counts I and II.

Judgment affirmed.

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA VIOLATIONS:

18 U.S.C. § 1962(d) v. RICO Conspiracy

18 U.S.C. § 1962(c) Racketeering

(1) EDWARD J. MACKENZIE, JR., 18 U.S.C. § 1349 Mail Fraud Conspiracy

18 U.S.C. § 1956(h) Money Laundering Conspiracy

18 U.S.C. § 1951 Extortion

18 U.S.C. § 1343 Wire Fraud

Defendant. 18 U.S.C. § 2(a) Aiding and Abetting

18 U.S.C. §§ 981, 982, 963, 28 U.S.C. § 2461 Criminal Forfeiture

INDICTMENT

THE UNITED STATES GRAND JURY in and for the District of

Massachusetts charges that:

1

Case 1:13-cr-10149-FDS Document 5 Filed 05/21/13 Page 1 of 44

COUNT ONE (Racketeering Conspiracy)

At all times relevant to this Indictment:

THE ENTERPRISE

1. The Boston Society of the New Jerusalem was chartered

in 1823 as one of the first Swedenborgian churches in

Massachusetts. The Boston Society of the New Jerusalem, Inc.

(hereinafter, "BSNJ") was a charitable religious non-profit

corporation established under the laws of the Commonwealth of

Massachusetts which operated as a church. BSNJ established

Bostonview Corporation, Inc. (hereinafter, "BVC") , which does

business in Massachusetts as a non-profit corporation, for the

specific purpose of holding title to property located at 130-140

Bowdoin Street, Boston, Massachusetts. The 130-140 Bowdoin

Street property encompassed both the Boston Society of the New

Jerusalem church and an approximately 18-story apartment

building with approximately 145 residential rental units

(hereinafter, "BVC Apartments"). These rental units generated

net income of approximately $1.4 million per year. Each year

since in or about 2006, BVC has remitted its net income to BSNJ.

2. BSNJ was run by a Board of Trustees, which was elected

by the church members. The Board of Trustees was responsible

for decisions regarding BSNJ's finances, the collection and

2


distribution of all funds for the support of public worship or

special programs, the maintenance of financial records, and the

preparation of a budget. As of in or about 2003, BSNJ also had

a "Director of Operations," who had responsibility and authority

for changes to the physical plant of the church. BVC was run by

a Board of Directors and was a wholly-owned subsidiary of BSNJ.

BSNJ, together with its wholly-owned subsidiary, BVC, will be

referred to herein as the "Church."

3. The Church constituted an "enterprise" as defined by

Title 18, United States Code, Section 1961(4), that is, an

association in fact of entities (hereinafter, "the enterprise").

The enterprise constituted an ongoing organization whose members

functioned as a continuing unit for a common purpose of

achieving the objectives of the enterprise. This enterprise was

engaged in, and its activities affected, interstate and foreign

commerce.

4. The Church is an exempt organization under Internal

Revenue Code Section 501 (c) (3) (hereinafter, "IRC Section

SOl(c) (3)"). Under the U. S. tax code, as an exempt

organization, the Church is prohibited from engaging in

activities that result in inurement of the Church's income or

assets to insiders. The prohibition against inurement to

3


insiders is absolute; therefore, any amount of inurement to

insiders is potentially grounds for loss of tax-exempt status.

THE DEFENDANT

5. EDWARD J. MACKENZIE, JR., 54, became a member of the

Church in approximately September 2002i in 2003, MACKENZIE

became the Church's "Director of Operations, " a salaried

position that was created especially for him and which he still

holds.

6. MACKENZIE was an officer of BSNJ and a Director of

BVC. In Massachusetts, officers and directors of non-profit

corporations must act in good faith and exercise fiduciary

duties of care and loyalty. Pursuant to Massachusetts General

Law Chapter 180, Section 6C, a "director ... shall perform his

duties as such ... in good faith and in a manner he reasonably

believes to be in the best interest of the corporation, and with

such care as an ordinarily prudent person in a like position

with respect to a similar corporation ... would use under similar

circumstances." A director may not improperly benefit from

transactions with the corporation.

THE RACKETEERING CONSPIRACY

7. From at least as early as in or before September 2002,

and continuing through at least in or about December 2012/

within the District of Massachusetts and elsewhere / EDWARD J.

4


MACKENZIE, JR., defendant herein l and others known and unknown

to the Grand Jury I being persons employed by and associated with

the Church I an enterprise engaged in l and the activities of

which affected l interstate and foreign commerce I did unlawfully

and knowingly conspire confederate and agree to violate TitleI

18 1 United States Code I Section 1962(c), that is, to conduct and

participate, directly and indirectlYI in the conduct of the

affairs of the enterprise through a pattern of racketeering

activity. The pattern of racketeering activitYI as that term is

defined by Title 18, United States Code, Sections 1961(1) and

1961(5)1 through which MACKENZIE and his co-conspirators agreed

to conduct and participate directly and indirectly in the

conduct of the affairs of the enterprise l consisted of multiple

acts: (a) indictable under Title 18, United States Code I

Section 1343 (wire fraud) i (b) indictable under Title 18 1 United

States Code I Section 1341 (mail fraud) i (c) indictable under

Title 18 1 United States Code I Section 1956 (money laundering) i

(d) indictable under Title 18 1 United States Code I Section 1951

(extortion); and (e) involving bribery I chargeable under Section

39 of Chapter 271 of the Massachusetts General Laws.

8. It was part of the conspiracy that MACKENZIE agreed

that a conspirator would commit at least two acts of

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racketeering activity in the conduct of the affairs of the

enterprise.

OBJECTS OF THE CONSPIRACY

9. It was a goal of the conspiracy for MACKENZIE and his

co-conspirators to become members of the enterprise and obtain

power and influence within the enterprise so that MACKENZIE and

his co-conspirators could defraud the Church of its considerable

financial holdings and profit from transactions involving the

Church.

10. Once MACKENZIE and his co-conspirators were in

positions of authority within the enterprise, they carried out a

scheme to defraud the Church and to obtain money and property

from the Church by means of false and fraudulent pretenses,

representations and promises, to enrich themselves and others at

the expense of the Church, and to personally enrich themselves

by soliciting and accepting bribes and kickbacks from vendors

doing business with the Church.

MANNER AND MEANS OF THE CONSPIRACY

It was a part of the conspiracy that:

11. MACKENZIE and co-conspirator Thomas J. KENNEDY

(another new Church member) knew that the Church had only a

small number of voting members, many of whom were elderly.

MACKENZIE became a full voting member of the Church in or about

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September 2002. Shortly after joining the Church, MACKENZIE and

KENNEDY devised a plan to gain control of the Church so that

they could defraud the Church of its considerable financial

holdings and profit from transactions involving the Church.

12. Accordingly, MACKENZIE and KENNEDY devised a scheme to

gain control of the Church by, among other things:

a. Inducing the then-Reverend to endorse MACKENZIE and KENNEDY's plan to take control of the Church by promising, and subsequently granting, him substantial remuneration and autonomy within the Church; and

b. Recruiting and using friends and family, some of whom had no interest in, or awareness of, the Church and its teachings, to become members, and creating phony membership applications for other new Church "members" who had no idea they had "applied" for membership in order to establish a voting maj ority to elect themselves into positions of authority within the Church.

13. At the annual Church members meeting in or about May

2003, MACKENZIE and KENNEDY assembled a sufficient voting bloc

to take control of the Church. Once in control, in or about

2003, MACKENZIE, KENNEDY, and their co-conspirators began moving

to consolidate and fortify their power, including, but not

limited to, the following: (a) removing certain incumbent

Trustees and Church officials who were perceived as obstacles;

(b) seceding from the General Convention and other umbrella and

parent organizations of the Swedenborgian Church in order to

7


obtain greater autonomy; (c) amending the Church's by-laws to

give MACKENZIE and KENNEDY greater authority and control; and

(d) creating the salaried position of "Director of Operations"

for the Church - a position for which MACKENZIE was hired in

2003 and continued to hold as of May 2013 and giving the

"Director of Operations" authority for changes to the physical

plant of the Church.

14. In addition to consolidating their power within the

Church, once in control, MACKENZIE and his co-conspirators, in

violation of their fiduciary obligations and the Church's IRC

Section 501(c (3) status, began voting to provide themselves and

their associates with substantial financial benefits, including,

but not limited to: (a) the purchase of at least four new

vehicles for, among others, MACKENZIE, KENNEDY, and a relative

of MACKENZIE; (b) cash awards for MACKENZIE's family members;

(c) a $50,000 "loan" to MACKENZIE to pay his personal legal

bills; and (d) tuition grants to family members of KENNEDY.

15. On or about December 12, 2003, the Church entered into

a five-year employment agreement with MACKENZIE to be the

Church's "Director of Operations," a position that had not

previously existed. The agreement provided MACKENZIE with a

starting salary of $100,000, annual salary increases in

accordance with the Consumer Price Index, performance bonuses, a

8


retirement plan, health insurance, and four weeks of paid

vacation (plus 11 paid holidays). In September 2006, the Board

of Trustees agreed to renew MACKENZIE's employment agreement for

another five years effective December 2008, and continuing

through December 2013. In 2012, MACKENZIE's salary and

compensation as the Church's "Director of Operations ll was

approximately $200,000.

16. Once in power, MACKENZIE began to systematically loot

the Church of its considerable financial assets through a

combination of fraud, deceit, extortion, theft, and bribery.

Moreover, MACKENZIE intimidated and threatened individuals who

were employed by and did work at the Church by in part, among

other things, providing them with signed copies of his 2003

autobiography, Street Soldier: My Life as an Enforcer for

Whi tey Bulger and the Boston Irish Mob (hereinafter, "Street

Soldierll ) In Street Soldier, MACKENZIE admitted to a lengthy•

criminal history, including burglary, robbery, armed assault,

and narcotics trafficking.

All in violation of Title 18, United States Code, Section

1962 (d) .

9


COUNT TWO (Racketeering)

17. paragraphs 1-6 and 9-16 are restated herein and

incorporated by reference.

18. From at least in or before September 2002 and

continuing through at least in or about December 2012, in the

District of Massachusetts and elsewhere, EDWARD J. MACKENZIE,

JR., defendant herein, together wi th others, known and unknown

to the Grand Jury, being persons employed by and associated with

the Church, did unlawfully and knowingly conduct and

participate, directly and indirectly, in the conduct of the

affairs of the Church, an enterprise which was engaged in, and

the activities of which affected, interstate and foreign

commerce, through the pattern of racketeering activity

particularly described below in paragraphs 19 through 56.

RACKETEERING ACT NUMBER ONE (Space propulsion Wire Fraud)

19. In or about Spring of 2004, MACKENZIE and KENNEDY

knowingly caused the Church to invest $200,000 of Church money

in a Florida corporation, Space propulsion Systems, Inc.

(hereinafter, "Space propulsion"). MACKENZIE and KENNEDY caused

the Church to invest $200,000 in Space Propulsion by

fraudulently misrepresenting that the $200,000 was an

investment, when it was primarily a means for MACKENZIE and

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KENNEDY to enrich themselves at the Church's expense. In fact,

MACKENZIE and KENNEDY had an agreement wi th Space Propulsion

that the Church's investment was conditional on an immediate

$80,000 kickback to MACKENZIE and KENNEDY, which MACKENZIE and

KENNEDY concealed from the Church.

20. From at least in or about Spring 2004, to at least on

or about June 8, 2004, MACKENZIE and others, known and unknown

to the Grand Jury, devised and intended to devise the above

described scheme and artifice to defraud the Church, and to

obtain money and property by means of materially false and

fraudulent pretenses, representations and promises.

21. On or about each of the dates set forth below, in

Boston, in the District of Massachusetts, in Jacksonville, in

the Middle District of Florida, and elsewhere, EDWARD J.

MACKENZIE, JR., defendant herein, aided and abetted by others,

known and unknown to the Grand Jury, for the purpose of

executing the scheme and artifice described above, caused to be

transmitted by means of wire communication in interstate

commerce the signals and sounds described below, anyone of

which alone constitutes the commission of Racketeering Act

11


Number One, in violation of Title 18, United States Code,

Sections 1343 and 2 (a) :

DATE DESCRIPTION

1A June 4, 2004 $200,000 wire MA to FL 1B June 7, 2004 $40,000 wire FL to MA (KENNEDY) 1C June 8, 2004 $40,000 wire FL to MA (MACKENZIE)

RACKETEERING ACT NUMBER TWO (College Tuition Mail Fraud)

22. The Church has long had a tuition grant program in

which the Church provided scholarships and tuition grants to the

families of Church members. Between approximately Winter 2005

and August 2008, MACKENZIE fraudulently caused the Church to pay

approximately $108,980 in tuition payments to Boston College and

Quinnipiac University on behalf of the children of an executive

at the property management company that managed the BVC

Apartments (hereinafter I "Tuition Recipient #1"). It was part

of the scheme that MACKENZIE falsely misrepresented to Tuition

Recipient #1 that the Church had expanded its tuition

reimbursement program to non-Church members / when in fact the

Church had not done so. MACKENZIE then encouraged Tuition

Recipient #1 to apply to the Church / s tuition program. In

return for using his influence to cause the Church to improperly

pay $108,980 in tuition payments on behalf of Tuition Recipient

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#1, MACKENZIE solicited and accepted from Tuition Recipient #1

approximately $20,000 in cash kickbacks.

23. From at least as early as in or about March 2005,

through in or about Augus t 2008, in the District of

Massachusetts, the District of Connecticut, and elsewhere,

EDWARD J. MACKENZIE, JR., defendant herein, aided and abetted by

others, known and unknown to the Grand Jury, devised and

intended to devise the above-described scheme and artifice to

defraud and obtain money and property by materially false and

fraudulent pretenses, representations, and promises.

24. On or about the dates listed below, in the District

of Massachusetts, the District of Connecticut, and elsewhere,

for the purpose of executing and attempting to execute the

above-described scheme and artifice to defraud and obtain money

and property by means of materially false and fraudulent

pretenses, representations and promises, MACKENZIE knowingly

caused to be placed in a post office and authorized depository

for mail matter a matter and thing to be sent and delivered by

the Postal Service, anyone of which mailings alone constitutes

the commission of Racketeering Act Number Two, in violation of

Title 18, United States Code, Sections 1341 and 2(a):

DATE CHURCH CHECK MAILING

2A January 1, 2006 $15,000 to BC (ck. # 2897)

13


2B August 3, 2006 $15,000 to BC (ck. # 3359) 2C January 4, 2007 $15,000 to BC (ck. # 3701) 2D June 141 2007 $15 / 000 to BC (ck. # 4064) 2E January 41 2008 $15 / 000 to BC (ck. # 4497) 2F July 10 1 2008 $15 / 000 to QU (ck. # 6323) 2G August 141 2008 $18 / 980 to BC (ck. # 6362)

TOTAL $108,980

RACKETEERING ACT NUMBER THREE (Check Stealing Mail Fraud)

25. Between in or about April 2006 and in or about June

2008 I MACKENZIE and KENNEDY came into physical possession of

seven checks made payable to either BSNJ or BVC. MACKENZIE and

KENNEDY then devised a scheme to steal the checks from the

Church. It was part of the scheme that in order to steal thel

checks l MACKENZIE and KENNEDY created a phony trust "BVCl

Trust. II MACKENZIE and KENNEDY used l among other things I the

creation of BVC Trust to open two sham Sovereign Bank accounts

in the names of BSNJ and BVC. When MACKENZIE and KENNEDY opened

the two sham Sovereign Bank accounts they provided the bankI

with addresses over which MACKENZIE and KENNEDY had exclusive

dominion and control. This allowed MACKENZIE and KENNEDY to

conceal the scheme to defraud from the Church by maintaining

control over the bank statements and financial records for the

two sham Sovereign Bank accounts. Once the sham Sovereign Bank

accounts were opened, it was part of the scheme that MACKENZIE

and KENNEDY fraudulently deposited seven checks payable to the

14


Church I totaling approximately $168 / 169.74 1 into the sham

Sovereign Bank accounts. After the seven checks were deposited l

MACKENZIE and KENNEDY I through a series of financial

transactions that were designed at least in part to conceal the

fraud shared the proceeds.1

26. From at least on or about April 26 I 2006 I until at

least on or about June 20 1 2008 1 at Boston l Canton I and

elsewhere in the District of Massachusetts EDWARD J. MACKENZIE,1

JR., defendant herein l aided and abetted by others known and1

unknown to the Grand Jury 1 devised and intended to devise the

above-described scheme and artifice to defraud and obtain money

and property by materially false and fraudulent pretenses I

representations and promises.1

27. For the purpose of executing and attempting to execute

the above-described scheme and artifice to defraud and obtain

money and property by materially false and fraudulent pretenses 1

representations and promises 1 MACKENZIE and KENNEDY knowinglyI

caused to be placed in a post office and authorized depository

for mail matter a matter and thing to be sent and delivered by

the Postal Service to wit: bank statements and other financiall

documents between 2006 and 2008 for the sham Sovereign Bank

1accounts in violation of Title 18 1 United States Code I Sections

1341 and 2(a).

15


RACKETEERING ACT NUMBER FOUR (Money Conspiracy)

28. In approximately April 2006 1 MACKENZIE created a sham

trust "Fillabuster Catering Trustfl (hereinafter 1 "FCT 11 ) based1

on a purposeful variation of the name of "Fill-A-Buster

Restaurant which had been located next to the Church for over1 fI

30 years. It was part of the conspiracy that in creating FCT 1

MACKENZIE falsely misrepresented on various documents that an

ex-girlfriend of his was the "trustee fl of FCT 1 and a signature

purporting to be that of his ex-girlfriend appears on FCT-

related documents. MACKENZIE's ex-girlfriend l however 1 had

flnever heard of FCT and was not familiar with the term "trustee 1

nor had she ever signed any document on behalf of FCT. Once the

FCT was established l MACKENZIE used the falsified FCT documents

to open a bank account in the name of FCT 1 for which MACKENZIE

had sole signatory authority. Once the FCT bank account was

established l MACKENZIE used the account to conceal from the

Church his affiliation with FCT 1 conceal the proceeds of

Racketeering Acts Numbers Three 1 Eight Fifteen l and Sixteen1 l

and conceal from the Internal Revenue Service more than

approximately $316 / 000 in income that he was paid by the Church

through FCT.

16


29. From at least in or before April 2006 and continuing

through at least in or about December 2012 1 in the District of

Massachusetts and elsewhere l EDWARD J. MACKENZIE, JR., defendant

Iherein l and others known and unknown to the Grand Jury I knowing

that the property involved in financial transactions represented

the proceeds of some form of unlawful activitYI did knowingly

conspire, confederate, and agree to conduct financial

Itransactions affecting interstate and foreign commerce, which

in fact involved the proceeds of mail fraud, in violation of

Title 18 1 United States Code I Section 1341, and commercial

bribery, in violation of Section 39 of Chapter 271 of the

Massachusetts General Laws I knowing that the transactions were

designed in whole and in part to conceal and disguise the

nature, the location l the source, the ownershipi and the control

of the proceeds of mail fraud I all in violation of Title 18,

United States Code, Section 1341 1 and commercial briberyl in

violation of Section 39 of Chapter 271 of the Massachusetts

General Laws I in violation of Title 18, United States Code I

Sections 1956(h) and 1956(a) (1) (B) (i).

RACKETEERING ACT NUMBER FIVE (Plumber #1 Commercial Bribery)

30. In or about Summer 2006 I the Church hired a large

commercial plumbing company (hereinafter I \\CPC tI ) to replace the

17


piping in the BVC Apartments. MACKENZIE also caused the Church

to hire "Plumber #1," a one-employee plumbing operation, to

"oversee" CPC despite the fact that Plumber #1' s hiring was

unnecessary to complete the pipe replacement job. Between July

2006 and October 2007, the Church paid Plumber #1 approximately

$123,808 to "oversee" the pipe replacement job. During that

same period, in return for using his influence within the Church

to help Plumber #1 maintain and obtain work from the Church,

MACKENZIE solicited and accepted thousands of dollars in cash

kickbacks from Plumber #1.

31. From at least in or about Summer 2006, until at least

in or about October 2007, in the District of Massachusetts, in

relation to transactions and matters concerning the business

affairs of an employer, principal, and beneficiary, to wit, the

Church, and as an agent and fiduciary of the Church, EDWARD J.

MACKENZIE, JR., defendant herein, solicited, accepted, and

agreed to accept payments from Plumber #1, who was not an

employee, principal, and beneficiary of the Church, upon an

agreement and understanding that such payments would influence

MACKENZIE's conduct, in violation of Section 39 of Chapter 271

of the Massachusetts General Laws.

18


RACKETEERING ACT NUMBER SIX (Floorer #1 Commercial Bribery)

32. Between 2006 and 2011 1 "Floorer #1'1 was the owner of a

greater Boston discount carpet and flooring company who was paid

approximately $356 / 000 by the Church for numerous carpet and

flooring-related jobs. During that same period , in return for

using his influence within the Church to help Floorer #1 obtain

and maintain flooring-related work at the Church , MACKENZIE

knowingly caused Floorer #1 to inflate his bids for work at the

Church by soliciting and accepting approximately $116 / 650 in

cash kickbacks from Floorer #1.

33. From at least in or about September 2006 1 until at

least in or about December in the District of

1Massachusetts in relation to transactions and matters

concerning the business affairs of an employer 1 principal, and

beneficiary, to wit, the Church, and as an agent and fiduciary

of the Church, EDWARD J. MACKENZIE, JR., defendant herein,

solicited, accepted, and agreed to accept payments from Floorer

#11 who was not an employee 1 principal 1 and beneficiary of the

Church 1 upon an agreement or understanding that such payments

would influence MACKENZIE's conduct 1 in violation of Section 39

of Chapter 271 of the Massachusetts General Laws.

19


RACKETEERING ACT NUMBER SEVEN (Aquarium Owner Commercial Bribery)

34. Between 2005 and 2011, "Aquarium Owner," the owner of

a greater Boston fish and aquarium retail store, billed the

Church, on average, approximately $25,000 - $30,000 per year for

aquarium services and associated maintenance. In approximately

March 2007, MACKENZIE fraudulently caused the Church to pay for

a high-end aquarium installed at MACKENZIE's residence in

weymouth, Massachusetts by Aquarium Owner. From the time the

aquarium was installed at MACKENZIE's residence in 2007, through

in or about 2011, in return for using his influence within the

Church to help Aquarium Owner obtain and maintain aquarium-

related work at the Church, MACKENZIE knowingly caused Aquarium

Owner to inflate his bids for work at the Church by soliciting

and accepting from Aquarium Owner approximately $3,000 per year

in concealed bribes and kickbacks that consisted of the

maintenance and replacement work performed on the aquarium

installed in MACKENZIE's residence (for which Aquarium Owner

never charged MACKENZIE) .

35. From at least in or about March 2007, until at least

in or about December 2011, in the District of Massachusetts, in



20




agreed to accept things of value, to wit, an aquarium installed

at his residence and related maintenance service and

parts/accessories, from Aquarium Owner, who was not an employee,

principal, and beneficiary of the Church, upon an agreement or

understanding that such things of value would influence



RACKETEERING ACT NUMBER EIGHT (Carpenter #1 Commercial Bribery)

36. Carpenter #1 is a self-employed carpenter who has run

his own commercial and residential general contracting company

in greater Boston for more than twenty years. Between

approximately Summer 2007 and December 2007, in return for using

his influence within the Church to help Carpenter #1 obtain and

maintain general contracting work at the Church, MACKENZIE

knowingly caused Carpenter #1 to inflate his bid for work at the

Church by soliciting and accepting approximately $24,000 in

kickbacks from Carpenter #1, some of which MACKENZIE directed be

in the form of checks payable to Fillabuster Catering, which

MACKENZIE caused to be deposited into the FCT account.

21


37. From at least in or about August 2007, until at least

in or about December 2007, in the District of Massachusetts, in





agreed to accept payments from Carpenter #1, who was not an


agreement or understanding that such payments would influence



RACKETEERING ACT NUMBER NINE (Carpenter #2 Commercial Bribery)

38. Carpenter #2 is a self-employed carpenter who has run

his own general contracting company in greater Boston for more

than two decades. Between approximately May 2007 and December

2010, Carpenter #2 was paid approximately $96,345 by the Church.

In return for using his influence within the Church to help

Carpenter #2 obtain and maintain general contracting work at the

Church, MACKENZIE solicited and accepted cash and in-kind

kickbacks from Carpenter #2, to wit, at least approximately

$20,500 in cash as well as carpentry work that was paid for by

22


the Church but was performed by Carpenter #2 at the residences

of MACKENZIE and a family member of MACKENZIE.

39. From at least in or about May 2007, until at least in

or about December 2010, in the District of Massachusetts, in





agreed to accept payments from Carpenter #2, who was not an


agreement or understanding that such payments would influence



RACKETEERING ACT NUMBER TEN (Carpenter #2 Extortion)

40. Not later than 2009, MACKENZIE gave Carpenter #2 a

signed copy of Street Soldier. In or about December 2010, in

connection with a job at the Church, when Carpenter #2 initially

attempted to provide MACKENZIE with only a $3,000 (instead of

the previously agreed-upon $6,000) cash kickback, MACKENZIE

swore at Carpenter #2, banged on the hood of Carpenter #2's car,

and put Carpenter #2 in fear for his physical safety. At that

point, Carpenter #2 gave MACKENZIE an additional $3,000 in cash.

23


41. From in or about at least 2009 and continuing until in

or about December 2010, within the District of Massachusetts,

EDWARD J. MACKENZIE, JR., defendant herein, did obstruct, delay,

and affect commerce and the movement of articles and commodities

in commerce by extortion, as those terms are defined in Title

18, United States Code, section 1951, that is, MACKENZIE

obtained property, to wit, United States currency, from

Carpenter #2 with Carpenter #2's consent, which consent was

induced by the wrongful use of actual and threatened force,

violence, and fear, in violation of Title 18, United States

Code, Section 1951.

RACKETEERING ACT NUMBER ELEVEN (Boiler Replacement Wire Fraud)

42. In approximately December 2010, after being advised

that MACKENZIE required a kickback of approximately 10% on all

work done at the Church, the owner of CPC inflated the bid he

submitted to the Church for a boiler replacement job to account

for the 10% kickback to MACKENZIE. In return for using his

influence within the Church to help CPC obtain and maintain the

boiler replacement job, MACKENZIE knowingly caused CPC to

inflate its bid for work at the Church by soliciting and

accepting an approximately $27,400 cash kickback from the owner

of CPC.

24


43. From at least in or about December 2010, to at least

on or about October/November 2011, MACKENZIE devised and

intended to devise the above-described scheme and artifice to

defraud the Church, and to obtain money and property by means of

materially false and fraudulent pretenses, representations and

promises.

44. On or about each of the dates set forth below, in the


JR., defendant herein, aided and abetted by others, known and

unknown to the Grand Jury, for the purpose of executing the

scheme and artifice described above, caused to be transmitted by

means of wire communication in interstate commerce the writings,

signals and sounds described below, anyone of which alone

constitutes the commission of Racketeering Act Number Eleven, in

violation of Title 18, United States Code, Sections 1343 and

2 (a) :

DESCRIPTION

llA 12/20/2010 a.m. E-mail from CPC to BVC IlB 12/20/2010 p.m. E-mail from CPC to BVC

25


RACKETEERING ACT NUMBER TWELVE (Boiler Replacement Commercial Bribery)

45. Paragraph 42 is restated herein and incorporated by

reference.

46. From at least in or about December 2010, to at least

on or about October/November 2011, in the District of

Massachusetts, in relation to transactions and matters

concerning the business affairs of an employer, principal, and

beneficiary, to wit, the Church, and as an agent and fiduciary

of the Church, EDWARD J. MACKENZIE, JR., defendant herein,

solicited, accepted, and agreed to accept payments from the

owner of CPC and the owner's associate, who were not employees,

principals, and beneficiaries of the Church, upon an agreement

or understanding that such payments would influence MACKENZIE's

conduct, in violation of Section 39 of Chapter 271 of the

Massachusetts General Laws.

RACKETEERING ACT NUMBER THIRTEEN (Booster Pump Wire Fraud)

47. In or about 2011, after being advised again that

MACKENZIE required a kickback of approximately 10% on all work

done at the Church, the owner of CPC inflated the bid he

submitted to the Church for a booster pump job to account for

the 10% kickback to MACKENZIE. In return for using his

influence within the Church to help CPC obtain and maintain the

26


booster pump job, MACKENZIE knowingly caused CPC to inflate its

bid for work at the Church by soliciting and accepting an

approximately $9,400 cash kickback from the owner of CPC.

48. From at least in or about July 2011, to at least on or

about August 2011, MACKENZIE devised and intended to devise the

above-described scheme and artifice to defraud the Church, and

to obtain money and property by means of materially false and








signals and sounds described below, anyone of which alone

constitutes the commission of Racketeering Act Number Thirteen,

in violation of Title 18, United States Code, Sections 1343 and

2 (a) :

DESCRIPTION

13A 7/12/2011 E-mail from CPC to Church 13B 8/4/2011 E-mail from CPC to Church 13C 8/4/2011 E-mail from CPC to MACKENZIE 13D 8/10/2011 E-mail from Church to CPC 13E 8/10/2011 E-mail from CPC to Church

27


RACKETEERING ACT NUMBER FOURTEEN (Booster Pump Commercial Bribery)


reference.

51. From at least in or about July 2011, until at least in

or about August 2011, in the District of Massachusetts, in





agreed to accept payments from the owner of CPC and the owner's

associate, who were not employees, principals, and beneficiaries

of the Church, upon an agreement or understanding that such

payments would influence MACKENZIE's conduct, in violation of

Section 39 of Chapter 271 of the Massachusetts General Laws.

RACKETEERING ACT NUMBER FIFTEEN (Painter #1 Wire Fraud)

52. In or about 2009, MACKENZIE asked Painter #1, a long

time friend of his, to submit a bid for painting work at the

Church, despite the fact that Painter #1 had little or no

previous painting experience. Between approximately May 2009

and October 2009, Painter #1' s company was paid approximately

$127,129 by the Church, including payment for painting work that

Painter #1 never performed but for which the Church, at

28


MACKENZIE's direction, was billed. In return for using his

influence within the Church to help Painter #1 obtain and

maintain the painting work at the Church, MACKENZIE knowingly

caused Painter #1 to inflate her bids for work at the Church by

soliciting and accepting at least approximately $24,000 in

kickbacks from Painter #1 and Painter #l's associates, a portion

of which MACKENZIE deposited into the FCT account.

53. From at least in or about May 2009, to at least in or

about October 2009, MACKENZIE devised and intended to devise the

above-described scheme and artifice to defraud the Church, and

to obtain money and property by means of materially false and


54. On or about the date set forth below, in the District

of Massachusetts and elsewhere, EDWARD J. MACKENZIE, JR.,

defendant herein, aided and abetted by others, known and unknown

to the Grand Jury, for the purpose of executing the scheme and

artifice described above, caused to be transmitted by means of

wire communication in interstate commerce the following writing,

signal and sound, in violation of Title 18, United States Code,

Sections 1343 and 2(a):

DESCRIPTION

9/1/2009 E-mail from MACKENZIE to Painter #1

29


RACKETEERING ACT NUMBER SIXTEEN (Painter #1 Commercial Bribery)


reference.

56. From at least in or about May 2009, until at least in

or about October 2009, in the District of Massachusetts, in





agreed to accept payments from Painter #1 and Painter #l's

associates, who were not employees, principals, and

beneficiaries of the Church, upon an agreement or understanding

that such payments would influence MACKENZIE's conduct, in

violation of Section 39 of Chapter 271 of the Massachusetts

General Laws.

All in violation of Title 18, United States Code, Sections

1962 (c) .

30


COUNT THREE (College Tuition Mail Fraud Conspiracy)

57. As set forth above in paragraph 221 which is restated

herein and incorporated by reference from at least in or about1

March 2005 1 through at least in or about August 2008 1 in the

District of Massachusetts the District of Connecticut and1 1

elsewhere EDWARD J. MACKENZIE, JR., defendant herein l with the1

intent to defraud l combined 1 conspired 1 confederated l and agreed

1with other persons known and unknown to the Grand Jury, to

devise the above-described scheme and artifice to defraud and

obtain money and property by materially false and fraudulent

pretenses, representations, and promises.



money and property by materially false and fraudulent pretenses,

representations, and promises I MACKENZIE and others, known and

unknown to the Grand Jury, knowingly caused to be placed in a

post office and authorized depository for mail matter a matter

and thing to be sent and delivered by the Postal Service 1 to

wi t: tuition payment checks from the Church to Boston College

and Quinnipiac University.

All in violation of Title 18, United States Code 1 Section

1349.

31


COUNT FOUR (Check Stealing Mail Fraud Conspiracy)

59. As set forth above in paragraph 25, which is restated

herein and incorporated by reference, from at least on or about

April 26, 2006, until at least on or about June 20, 2008, at

Boston, Canton, and elsewhere in the District of Massachusetts,

EDWARD J. MACKENZIE, JR., defendant herein, with the intent to

defraud, combined, conspired, confederated, and agreed with

other persons, known and unknown to the Grand Jury, to devise



representations, and promises.




representations, and promises, MACKENZIE and others, known and

unknown to the Grand Jury, knowingly caused to be placed in a

post office and authorized depository for mail matter a matter

and thing to be sent and delivered by the Postal Service, to

wit: bank statements and other financial documents between 2006

and 2008 for the sham sovereign Bank accounts.


1349.

32


COUNT FIVE (Money Laundering Conspiracy)


herein and incorporated by reference, from at least in or before

April 2006 and continuing through at least in or about December

2012, within the District of Massachusetts and elsewhere, EDWARD

J. MACKENZIE, JR., defendant herein, and others known and

unknown to the Grand Jury, knowing that the property involved in

financial transactions represented the proceeds of some form of

unlawful activity, did knowingly conspire, confederate, and

agree to conduct financial transactions, affecting interstate

and foreign commerce, which in fact involved the proceeds of

mail fraud, in violation of Title 18, United States Code,

Section 1341, and commercial bribery, in violation of Section 39

of Chapter 271 of the Massachusetts General Laws, knowing that

the transactions were designed in whole and in part to conceal

and disguise the nature, the location, the source, the

ownership, and the control of the proceeds of mail fraud, all in

violation of Title 18, United States Code, Section 1341, and

commercial bribery, in violation of Section 39 of Chapter 271 of

the Massachusetts General Laws.


1956 h and 1956 (a) (1) B i .

33


COUNT SIX (Carpenter #2 Extortion)


herein and incorporated by reference, from in or about at least

2009 and continuing until in or about December 2010, within the

District of Massachusetts, EDWARD J. MACKENZIE, JR., defendant

herein, did obstruct, delay, and affect commerce and the

movement of articles and commodities in commerce by extortion,

as those terms are defined in Title 18, United States Code,

section 1951, that is, MACKENZIE obtained property, to wit,

Uni ted States currency, from Carpenter #2 with Carpenter #2' s

consent, which consent was induced by the wrongful use of actual

and threatened force, violence, and fear.


1951.

34


COUNTS SEVEN AND EIGHT (Boiler Replacement Job Wire Fraud)


herein and incorporated by reference, from at least in or about

December 2010, to at least in or about October/November 2011,

MACKENZIE devised and intended to devise the above-described

scheme and artifice to defraud the Church, and to obtain money

and property by means of materially false and fraudulent

pretenses, representations and promises.







signals and sounds described below:

COUNT DESCRIPTION

7 8

12/20/2010 12/20/2010

a.m. p.m.

E-mail E-mail

from from

CPC CPC

to BVC to BVC


1343 and 2(a).

35


COUNTS NINE THROUGH THIRTEEN (Booster Pump Job Wire Fraud)



July 2011, to at least in or about August 2011, MACKENZIE

devised and intended to devise the above -described scheme and

artifice to defraud the Church, and to obtain money and property

by means of materially false and fraudulent pretenses,

representations and promises.







signals and sounds described below:

COUNT DESCRIPTION

9 7/12/2011 E-mail from CPC to Church 10 8/4/2011 E-mail from CPC to Church 11 8/4/2011 E-mail from CPC to MACKENZIE 12 8/10/2011 E-mail from Church to CPC 13 8/10/2011 E-mail from CPC to Church


1343 and 2(a).

36


COUNT FOURTEEN (Painter #1 Wire Fraud)



May 2009, to at least on or about October 2009, MACKENZIE

devised and intended to devise the above-described scheme and

artifice to defraud the Church, and to obtain money and property

by means of materially false and fraudulent pretenses,

representations and promises.

68. On or about September 1, 2009, in the District of

Massachusetts and elsewhere, defendant EDWARD J. MACKENZIE, JR.,

defendant herein, aided and abetted by others, known and unknown

to the Grand Jury, for the purpose of executing the scheme and

artifice described above, caused to be transmitted by means of

wire communication in interstate commerce the following writing,

signal and sound, to wit, an e-mail from MACKENZIE to Painter

#1.


1343 and 2 (a) .

37


RACKETEERING FORFEITURE ALLEGATIONS 18 U.S.C. § 1963

The Grand Jury further charges that:

69. Upon conviction of one or more of the offenses in

violation of 18 U.S.C. § 1962 as charged in Counts One and Two

of this Indictment, EDWARD J. MACKENZIE, JR., defendant herein,

shall forfeit to the United States of America pursuant to 18

U.S.C. § 1963 (a) :

a. all interests the defendant has acquired and maintained in violation of 18 U.S.C. § 1962, wherever located, and in whatever names held;

b. all interests in, securities of, claims against, and properties and contractual rights of any kind affording a source of influence over, any enterprise which the defendant has established, operated, controlled, conducted, and participated in the conduct of, in violation of 18 U.S.C. § 1962; and

c. all property constituting, and derived from, any proceeds which the defendant obtained, directly and indirectly, from racketeering activity and unlawful debt collection in violation of 18 U.S.C. § 1962.

70. The property to be forfeited includes, but is not

limited to, the sum of approximately $1 million, which

represents the proceeds of such violations.

71. If any of the property described in paragraph 69

hereof as being forfeitable pursuant to 18 U.S.C. § 1963, as a

result of any act and omission of the defendant

a. cannot be located upon the exercise of due diligencei

38


b. has been transferred to, sold to, or deposited with a third party;

c. has been placed beyond the jurisdiction of this Courti

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided without difficultYi

it is the intention of the United States, pursuant to 18 U.S.C.

§ 1963 (m), to seek forfeiture of any other property of the

defendant up to the value of the property described in paragraph

69 above, including but not limited to the following:

• the real property located at 955 Pleasant Street, Unit 1, Weymouth Massachusetts, including all buildings and appurtenances thereon, more particularly described in a deed recorded at Book 24132, Page 189 at the Norfolk County Registry of Deeds.

All pursuant to Title 18, United States Code, Section 1963.

39


FRAUD AND EXTORTION FORFEITURE ALLEGATIONS 18 U.S.C. § 981 and 28 U.S.C. § 2461


72. Upon conviction of one or more of the offenses in

violation of 18 U. S. C. §§ 1343, 1349 and 1951, as charged in

Counts Three, Four, and Six through Fourteen of this Indictment,

EDWARD J. MACKENZIE, JR., defendant herein, shall forfeit to the

United States of America pursuant to 18 U.S.C. § 981(a) (1) (C)

and 28 U.S.C. § 2461(c), any property, real or personal, which

constitutes or is derived from proceeds traceable to such

violations.


hereof as being forfeitable pursuant to 18 U.S.C. § 981(a) (1) (C)

and 28 U.S.C. § 2461(c), as a result of any act and omission of

the defendant

a. cannot be located upon the exercise of due diligence;


c. has been placed beyond the jurisdiction of this Court;


e. has been commingled with other property which cannot be divided without difficulty;


§ 2461(c), to seek forfeiture of any other property of the 40




• the real property located at 955 Pleasant street, Unit 1, Weymouth Massachusetts, including all buildings and appurtenances thereon, more particularly described in a deed recorded at Book 24132, Page 189 at the Norfolk County Registry of Deeds.

All pursuant to Title 18, United States Code, Section 981

and Title 28, United States Code, Section 2461.

41


MONEY LAUNDERING FORFEITURE ALLEGATIONS 18 U.S.C. § 982


74. Upon conviction of the offense in violation of 18

U.S.C. § 1956, as charged in Count Five of this Indictment,

EDWARD J. MACKENZIE, JR., defendant herein, shall forfeit to the

United States of America pursuant to 18 U.S.C. § 982(a) (I), any

property, real or personal, involved in such offense, and any

property traceable to such property.


hereof as being forfeitable pursuant to 18 U.S.C. § 982(a) (1),

as a result of any act and omission of the defendant

a. cannot be located upon the exercise of due diligence:


c. has been placed beyond the jurisdiction of this Court;


e. has been commingled with other property which cannot be divided without difficultYi


§ 982(b, to seek forfeiture of any other property of the



42


• the real property located at 955 Pleasant Street, Unit I, Weymouth Massachusetts, including all buildings and appurtenances thereon, more particularly described in a deed recorded at Book 24132, Page 189 at the Norfolk County Registry of Deeds.

All pursuant to Title 18, united States Code, Section 982.

43


A TRUE BILL

FOREPERSON OF THE GRAND JURY

TORNEY

DISTRICT OF MASSACHUSETTS; May __:2_\___, 2013.

Returned into the District Court by the Grand Jurors and filed.

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r;(cl l (/3

44


Church on The Hill (Swedenborgian) The Boston Society of the New Jerusalem, Inc.140 Bowdoin Street ~ Beacon Hill ~ Boston, MA 02108 ~ www.churchonthehillboston.org

April 2011Vol. VIII, Issue 4

Jesus said ”Come to me, all you who are weary and burdened, and I will give you rest. Take my yoke upon you and learn from me, for I am gentle and humble in heart, and you will find rest for your souls. For my yoke is easy and my burden is light.” MaAhew 11:28

Spring is here!!!

http://www.churchonthehillboston.org


NEWSLETTER OF THE BOSTON CHURCH OF THE NEW JERUSALEM

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GOALS AND OUR LIFE AS A CHURCH

Seeking to be guided by love of God, love of others, being in community, seeking to be of service. Church services and classes being vital and central. Nurturing teamwork and community throughout the church. The church welcoming diversity of people working together as one. Developing a pervasive spirit of caring in the church community. The church developing as welcoming of all generations (from children to senior). Concerted efforts to involve young people more fully in the life of the church. Perhaps with aid from adults, having leadership emerge from young people. Involvement of young people in service projects in the community. Strengthening of programs for seniors, drawing on resources both within and outside the church. Developing processes for ministry preparation. Growth of participation from the congregation in the church activities.

MinistersRev. Dr. J. Ted Klein, Senior Pastor

Executive OfficialsMary Guarino, PresidentDiane Williams, Vice PresidentRobert von Wolfgang, Chairman of the Board of TrusteesSusanne Rogers, TreasurerMichael Bancewicz, Secretary

DirectorsEdward J. Mackenzie, Jr., Director of Operations

Emeritus OfficialsMichael Latkowitch, President Emeritus

Anna Hunt Latkowitch, Church Council Emeritus

MusicCarlton Doctor, Minister of Music

Victor Cayres de Mendonca, Organist and Pianist

Michael Bancewicz, Acting EditorCraig Williams, Assistant Editor

New Jerusalem ChurchCirca 1845

The foundation of the Boston Society of the New Jerusalem (BSNJ) can be traced back to 1784 and the Green Dragon Tavern in Boston. It was then and there that admirers of, and those interested in learning more about, Emanuel Swedenborg first met to hear a lecture on Swedenborg by James Glen. In 1818, twelve people, some of whom were among the early “Green Dragon Tavern crowd,” organized a Swedenborgian Church in the city. Chartered in 1823, the Boston Society of the New Jerusalem, Inc. is the first Swedenborgian Church established in Massachusetts. Members of the Church met at several locations before finally settling in 1845 at its present location atop Beacon Hill. The location inspired the name by which many today know the society: the Church on the Hill (Swedenborgian). Through the years, noted BSNJ members include Timothy Harrington Carter, publisher, and founder of the Old Corner Book Store; Sampson Reed, writer and mentor of Ralph Waldo Emerson; Lydia Maria Child, author, social activist and abolitionist; Warren Felt Evans, writer and healer;

HISTORY OF THE CHURCH

Theophilus Parsons, dean of Harvard Law School; Otis Clapp, apothecary, publisher, member of the Massachusetts House of Representatives, co-founder of The Massachusetts Institute of Technology (M.I.T.), Boston University, and and founder of The Home for Little Wanderers; Theophilus P. Chandler, architect; Clarence Barron, financier, editor of the Wall Street Journal, and president of Dow Jones; George James Webb, hymnologist; and The Honorable Malcolm Nichols, Mayor of Boston. A beautiful Gothic Revival structure served the membership until the 1960s when it was replaced with a new Church building and an eighteen story high- rise apartment. Today, the main sanctuary of the Church is accessible from Bowdoin Street. The Church has also served as a place of worship and gatherings for the local Muslim Community and other faith-based communities. The Church has organizes and runs many programs to meet the needs of the Church community and larger surrounding neighborhood.

Use of the Church facility is offered to human service and outreach organizations.

CHURCH ON THE HILL - ESTABLISHED 1818

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MESSAGE FROM THE SENIOR PASTOR

Dear Members and Friends of the Church on the Hill:

In April there is a fuller and fuller coming of spring. The growth of buds, the blooming of flowers, the growth of leaves, the births of creatures are all part of spring. In our own lives we can enter seasons of spring, where new life takes shape with us and in our connecCons with others.

This month begins with the final Sundays of Lent, a season for searching into what is happening in our lives, where we are going, and what needs to change. Then we enter three observances so important in the ChrisCan year – Palm Sunday, Maundy Thursday, and Easter. We can recall the events in the life of Jesus remembering connecCons with our own lives.

This is a Cme of important change and growth in the church. We are seeking to strengthen connecCons within the church community, outreaching to members. Also the church is building connecCons beyond the church community in finding more ways of responding to needs and being of service.

Love and Best Wishes to Each of You,

Ted

NOTICE FROM THE SENIOR PASTORRev. Dr. Ted Klein

Please pray for the people of Japan and all others in need!

The congregation collections for April and May will be donated as follows:

April collections will go for relief of the people of Japan.

May collections will go to the Walk For Hunger.

The Oasis Coalition of Boston in collaboration with Suffolk University's S.O.U.L.'s Program have organized a health fair featuring many service providers and health organizations around the city of Boston.

The Fair will be open to all women with a special emphasis to our newly housed, poor and homeless.

There will be gift packages available for attendees that will include toiletries etc...

Food and snacks will be provided by the Suffolk Students. Please, Please spread the word!

Women’s Health FairFriday April 8th

12 Noon until 5:00 PM


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Walk For HungerMay 1, 2011

The Walk for Hunger is an annual tradition and a rite of spring in Massachusetts! Join 40,000 caring friends and neighbors and raise money for those struggling to make ends meet. Since 1969, The Walk for Hunger has been a tradition in Massachusetts. Today, the Walk has become the country's oldest continual pledge walk and the largest one-day fundraiser to alleviate local hunger. On the first Sunday in May each year, more than 40,000 Walkers and 2,000 Volunteers start off from the Boston Common to make a difference in the lives of our neighbors. In Massachusetts, more than 660,000 people do not have enough food to eat. The Walk for Hunger raises millions of dollars for the 400 emergency food programs that support families in crisis. The Walk is still looking for volunteers, whether you want to walk, hand out supplies, or work the finish line, the more help the better!

Our own Mike Bancewicz, Maria McKenzie, and Donald Gonzalez will be walking this year. Also, Rob Day and Donnie MacDougall will be working at the finish line. To join team Church on the Hill as a volunteer or walker, call the Church. The Walk for Hunger is a nationally respected event where all proceeds go towards making sure that no one goes hungry.

Every donation and volunteer effort goes a long way and we hope that you can help make a difference!

For More information, including how to donate and sign up to volunteer, visit www.projectbread.org or www.churchonthehillboston.org

http://www.projectbread.org/site/PageServer?pagename=help_fundedagencies_list




http://www.projectbread.org

http://www.projectbread.org




5

It brings me comfort and opCmism that our Lord did not use the language of the streets – only ”hang” with the morally upright ciCzens of society. He did not only socialize with those who followed God’s law and lived within society’s law.

As well, to our Lord, no person had more claim to heaven based on income or social status.

Jesus Christ lived with and knew the sinners and the saints. He lived with and knew those of means and privilege. And he lived with and knew all so well the outcast of society -‐ the downtrodden, the poor, the oppressed. His name and that of a prosCtute, Mary Magdalene, are forever linked not only in tradiCon or our Faith, but also in that of our civilizaCon. He did not mind.

Our Lord was put to death by the state. He was crucified between two criminals who were suffering the same fate. Because one of the criminals believed – and earnestly sought forgiveness – Jesus told him he would be saved.

Think about it – what faith has as its primary symbol the Cross – an instrument of state sancConed torture and capital punishment?

I believe that salvaCon and redempCon comes to different people in different ways. But I know that the support and understanding and the enlightenment, I have found in this faith, among you, in this house, feels good and right and full of promise.

I come from a tough background and knew a whole slew of abuse. You see, I was the downtrodden and poor that Christ loved. I was the criminal that Christ saved.

Walking into this church or listening to Rev. Dr. Ted Klein for the first Cme might not have made me Saul geYng hit with the divine light on the way to Damascus, but it was a start of something important, it really was.

You see the life I lived has been complex

and one of the streets. It has o[en been down and dirty. I think that the life of Emanuel Swedenborg appeals to me because he was a scienCst, philosopher, and theologian. He was a man of this world living to improve society and believing in salvaCon. He was real – and a man of God. This resonates with me in a big way.

The journey conCnues. We can all be happy and most grateful for the blessings that have been given to us. Let us be grateful for all of you helping each other on our journey to become a be]er Father, Brother, Sister, Mother and contributor to Society.

Thank you God and Rev. Klein, I will do my best to be worthy of it.

Edward MackenzieDirector of Opera>ons

Edward J. Mackenzie Jr Message given to Church on the Hill

March 20, 2011


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SOME THOUGHTS ON REBIRTH

Rev. Dr. Ted Klein

During this Cme of Spring and as the Season of Lent begins, we can reflect on rebirth in our lives and lives of others. We can observe new life breaking out in nature, and that new life can picture new life breaking out within and among us.. For example, a flower may picture new life in a connecCon among people, and the growth from a seed the beginnings of something new spiritually.

Pictured in scriptures are a person receiving a new heart (Ezekiel 11:19) and persons being born of the spirit (John 3:5). If we are in a process of rebirth, we are gradually being transformed, becoming a new person. Our part in this process is to turn from what we find with us that contributes to harm and toward what contributes to good. For example, we may be tangled and blind as we are caught up in self concern. Recognizing that we need God and others to change, we may resist the self concern and move into truly caring for others.

Swedenborg compares a person being reborn to the growth of a tree from seed and to the growth of a tree through leaves, blossoms, and fruit (Swedenborg, Arcana CoelesCa, no. 5115:2). With rebirth, guided by God and with our conCnuing efforts, there is progression and growth.

Rebirth as an overall direcCon goes with specific turnings in our lives, turnings from what harms and blocks to what benefits and serves. Turning in one area of our life may make it easier to turn in other areas. Even when we stumble and fall, we can recover and go forward, together with God and others.

CLOSING PRAYER

God. Help us to consider steps we need to take, turnings needed in our lives. Help us, joining with God and others, to move forward in a path of rebirth. Amen

Cooking ClassesMondays from 4-‐ 6

The Church on the Hill is providing space for a cooking class that will meet weekly at 4 PM in our kitchen. The class, facilitated by Marylou Pierron, will be offering newly housed people cooking lessons as well as advice on how to cook , healthy, easy to prepare meals on a budget. Anyone is welcome to join. We hope this can help inspire more people to cook healthy meals on their own.


8

Roland Mills received his B.M. in Vocal Performance from Northern Arizona University. He is a tenor studying classical voice with Dr. Rebecca Folsom, and currently attends the Boston Conservatory of Music seeking a Masters Degree. He currently holds a position in the music history department of the same school working as a teachers’ assistant, and maintains a voice studio at the Boston Arts Academy. His recent performances include leading roles in Britten's The Rape of Lucretia, Die Zauberflöte, and Gianni Schicchi, which he performed in Italy. His future Aspirations include performing on the greatest of operatic stages, teaching voice at the college level, and establishing a school of music in Trinidad, the country of his birth.

Meet The Choir...Some Thoughts on

Resurrection

Late in April we will be celebrating Easter. In our tradition we think of Easter and the resurrection of Jesus. What are resurrections in our lives? How does the resurrection of Jesus relate to our lives?

In the rebirths of spring, the break out of new life, we can see kinds of resurrection. Life continues, new life emerges.

According to our beliefs each of us, at death, continues on in a new life. We are risen and continue as spiritual beings, with a chance to grow more and more fully into the person we can be.

We can approach Jesus as continually with us as we face challenges and find new life in this world. In that way resurrection can happen over and over again in our lives.

God, help raise us from darkness to light, from coldness to warmth, from fear to freedom, from self concern to love and caring. Amen.

Rev. Dr. Ted KleinSenior Pastor

Roland Mills


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From the Editor

Greetings!March was

an eventful month and April/May look to be even more dynamic. We will be hosting a Womenʼs Health fair (see page 3). A Jack and Jill Baby Shower (page 10) Guest Minister Marion Easterling (page 10) Walk for Hunger (page 4) and of course the arrival of our long awaited Steinway piano plus much more. On any given day the church is buzzing with some kind activity, though some times distracting, it is evident that we are blessed with success in building the mission of the church! Please see the calendar on page 15 for events of the Easter Season.

A contingency from the church attended CMMʼs 45 Annual Meeting and Awards Dinner. Speaking of CMM, they are awarding us their first Volunteerism Achievement Award! On March 20th we had our fourth “Laity in the Pulpit” this one being led by Eddie Mackenzie with participation from many others. The music, message and inter-activeness made this one very memorable. Being out of town I was sorry to have missed Rev. Manikkaʼs message celebrating Womenʼs History Month, but I have heard that the message was strong and well received.

Congratulations to Mary Guarino for being the winner of last months “Can you name whoʼs who” contest having been able to name 11 of the 12 photos. She will receive a $50 gift card to Scollay Square Restaurant. We are having another contest this month (page 11) and the winner who guesses the most will win a gift card to the 21st Amendment. Call Craig or me at the office or mail in your answers, Good luck!

Blessings,Mike

Our New Piano!

The Church will be receiving our newly refurbished Steinway Piano on Thursday, March 31. We are very excited to hear how the sound will enhance our growing Sunday Services along with our upcoming Spring Concert, which will be held at the Church on May 15. Mike, Carlton, and Victor travelled to New York City to personally see and hear the piano and were very pleased and excited with what they heard. It is a 100 year old piano which was refurbished, by hand, and completely redone to make it visually stunning as well as upping the sound quality. Victor is ecstatic to finally be able to put this piano to use during the Church Service on Sunday, April 3.


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Correspondence

A Jack and Jill baby shower will be held at the Church on the Hill for Felicia Vega, who has applied for Church Membership, on April 10 at 1PM. Church Members are invited to make this a special day!

On Sunday, April 10, we will have a Special Guest Minister, Rev. Marion Easterling. Marion is the Senior Pastor at Old West Church on Cambridge Street in Boston. He has served as a pastor in Albuquerque, New Mexico and Colorado Springs, Colorado. In his current appointment, he is serving Old West Church, United Methodist of Boston, Massachusetts.

Baby Shower


11

Guess Who? Congratulations to Mary Guarino for winning last month.She guessed 11 out of 12. Tied for second were Terry Mazzulli and Anne Klein with 10 out of 12. The answers were from left to right and top to bottom;

Rosie the Riveter, Rosa Parks, Mother Teresa, Eleanor Roosevelt, Helen Keller, Harriet Tubman, Maya Anjelou, Indira Gandi, Golda Meir, Rachel Revere, Sacagawea, Edith Piaf. Aprilʼs winner will get a $50 gift card to the 21st Amendment.

SWEDENBORG READING New Life in People and in Nature “… when people are being reborn, spiritual life flows into them, just as when a tree is budding, its life flows in by heat from the sun. One who is born a person is in the Word throughout compared to beings in the vegetable kingdom, especially trees; and this is because the whole vegetable kingdom, as well as the animal kingdom, represents such things as are in people. (Arcana Coelestia, no. 5115)


12

A little boy came up to his mother in the kitchen one evening while she was fixing supper, and handed her a piece of paper that he had been writing on. After his Mom dried her hands on an apron, she read it, and this is what it said:

For cutting the grass: $5.00 For cleaning up my room this week: $1.00 For going to the store for you: $.50 Baby-sitting my kid brother while you went shopping: $.25 Taking out the garbage: $1.00 For getting a good report card: $5.00 For cleaning up and raking the yard: $2.00 Total owed: $14.75

Well, his mother looked at him standing there, and the boy could see the memories flashing through her mind. She picked up the pen, turned over the paper he'd written on, and this is what she wrote:

For the nine months I carried you while you were growing inside me: No Charge For all the nights that I've sat up with you, doctored and prayed for you: No Charge For all the trying times, and all the tears that you've caused through the years: No Charge For all the nights that were filled with dread, and for the worries I knew were ahead: No Charge For the toys, food, clothes, and even wiping your nose: No Charge

Son, when you add it up, the cost of my love is: No Charge.

When the boy finished reading what his mother had written, there were big tears in his eyes, and he looked straight at his mother and said, "Mom, I sure do love you." And then he took the pen and in great big letters he wrote: "PAID IN FULL".

Simple Acts of Kindness...

http://www.inspireme.net/inspirational-stories/mothers_love.htm











13

Oasis Book Club meets with Author Lara Bricker after reading her book Lie After Lie.

On March 8th we had the pleasure of inviting Lara Bricker, the author of our last reading selection, to the group for a Q&A session.

Lara is a freelance writer currently residing in Exeter, New Hampshire. This selection was suggested by Michael Bancewicz, an acquaintance of Lara. Lie After Lie: the true story of a master of deception, betrayal, and murder is a true crime story detailing the murder of thirty-one year Julie Keown. Her story book marriage to husband James Keown took a horrific turn when James began poisoning Julie with anti-freeze disguised in Gator-Aide bottles. Her subsequent death resulted in an investigation that began in Waltham, Massachusetts and ended in Missouri from where the couple originated. It’s a chilling story and a great read.

Our current reading selection is Mystic River penned by Boston native Dennis Lehane. We are in the promising process of inviting Mr.

Lehane sometime in May to discuss his book, too.

The Oasis Coalition of Boston wishes to extend an invitation welcoming all those interested in attending the book club. Again, we meet each and every Tuesday at 10:am. Books are provided by Oasis at no cost to attendees. Coffee and doughnuts are provided as well.

The Oasis book club is eternally grateful to the Church on the Hill, Senior Pastor Rev. Dr. Ted Klein, Director of Operations Edward J. Mackenzie Jr. and Administrator Michael Bancewicz for their combined hospitality, not only for the book club but for all the Oasis programs housed here at 140 Bowdoin Street.

The Oasis Coalition of Boston book club is hosted by Church on the Hill each Tuesday between the hours of 10 AM and 12 PM.

Rob Day

Her storybook marriage to husband James Keown took a horrific turn when ... from the book “Lie After Lie”

Ned Carlton, Lara Bricker and Rob Day


14

The Streets Are Ours!The Oasis Coalition of Bostonʼs Board of

Directors.Donnie MacDougall, Rob Day, Dr. Debra Harkins David Fisher, Chair and Michael Bancewicz. Not seen in the photo is newly appointed Treasurer Susanne Rogers.

Mike preparing braciole.

Boston Youth Organizing Project meet at Church on the Hill before lobbying at the State House.

Rev. Manikka Bowman was our Guest Leader on March 20 for Womenʼs History Month.

A weekly screenwriting class that meets in the Church every Wednesday 4-6 PM. The class is run by Megan Rice, a student at Emerson College.


15

Church Calendar Events 2011All are welcome. Come as you are.

AprilSunday, April 3 9:45 AM Swedenborg Class with Rev. Dr. Ted Klein

11:00 AM Church Service with Rev. Dr. Ted Klein

Wednesday, April 6 5:00 PM Church Council Meeting

6:00 PM Board of Trustees Meeting

Sunday, April 10 9:45 AM Bible Reflection

11:00 AM Church Service with Rev. Marion Easterling

Sunday, April 17 9:45 AM Palm Sunday. Swedenborg Class with Rev. Dr. Ted Klein


Wednesday, April 20 12:00 Noon Senior Lunch

Thursday, April 21 6:00 PM Maundy Service and Communion with Rev. Dr. Ted Klein

Sunday, April 24 11:00 AM Easter. Easter Service with Rev. Dr. Ted Klein

MaySunday, May 1 9:45 AM Bible Reflection

11:00 AM Church Service and Communion with Rev. Dr. Ted Klein

Wednesday, May 4 5:00 PM Church Council Meeting

6:00 PM Board of Trustees Meeting

Sunday, May 8 9:45 AM Swedenborg Class with Rev. Dr. Ted Klein

11:00 AM Mothers Day. Church Service with Rev. Dr. Ted Klein

Sunday, May 15 9:45 AM Bible Reflection

11:00 AM Spring Choir Concert

Wednesday, May 18 12:00 Noon Senior Lunch

Sunday, May 22 9:45 AM Swedenborg Class with Rev. Dr. Ted Klein

11:00 AM Church Service with Dr. Mary Kay Klein

Sunday, May 29 9:45 AM Bible Reflection


16

Church on The Hill (Swedenborgian) The Boston Society of the New Jerusalem, Inc.

140 Bowdoin Street, Beacon HillBoston, MA 02108-2799

Check Out The New Website at www.churchonthehillboston.org

“It is my mission to help in the breaking down of classes, and to make all men feel as if they were brethren of the same family, sharing the same rights, the same capabilities, and the same responsibilities. While my hand can hold a pen, I will use it to this end; and while my brain can earn a dollar, I will devote it to this end.” Lydia Maria Child

Lydia Maria Child (1802-1880)Member of the ChurchWriter, Author, Abolitionist, Civil Rights AdvocateWriter of “Over the River”

Spiritual

Steve Ellis - Ted Klein - Edward MacKenzie - 02-27-2015