A 2017 letter to then-Father Frank Pavone warned the now-laicized leader of Priests for Life that his bishop had decided to ask the Vatican to dismiss him from the clerical state, and gave the priest an opportunity to request laicization of his own accord. The letter said that Pavone had been consistently disobedient to ecclesiastical authorities, and had left Bishop Patrick Zurek of Amarillo with no hope of engaging constructively with Pavone.
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