This post contains an excerpt from the report “A year of devastation of the rule of law”, published by the Ordo Iuris Institute on December 13, 2024. The full report can be found at https://en.ordoiuris.pl/civil-liberties/year-of-devastation-of-rule-of-law-in-poland
Main theses:
From March 26 to October 24, 2024, Father Michal Olszewski was put in pre-trial detention as a catholic priest who was the chairman of the Profeto foundation when this foundation received tens of millions of zlotys in funding from the government’s Justice Fund for the construction in Warsaw of the Archipelag center for victims of violence.
According to the accounts of both the detainee and his defense attorney, Father Olszewski repeatedly received terrible treatment from the authorities – it was made difficult for him to contact his lawyer, he was handcuffed without reason, food was denied for dozens of hours and the use of the restroom was impeded.
Adam Bodnar’s prosecutors also attempted to unlawfully deprive Father Olszewski of his self-appointed defense attorney Krzysztof Wąsowski by suggesting that the latter was a witness in the case, not a defense attorney.
The conduct of the law enforcement agencies subordinate to Minister of Justice Adam Bodnar and Minister of Internal Affairs and Administration Marcin Kierwiński violated a number of guarantees set forth in applicable laws – the Constitution, laws and international agreements.
1. The course of the proceedings so far
On January 30, 2024, the National Prosecutor’s Office announced that on that day a team of investigators was appointed to investigate the proper management and disbursement of funds from the so-called Justice Fund[1]. On February 19, an investigation was launched[2] into an act committed under Article 231 § 1 and 2 of the Criminal Code[3].
On March 27, the National Prosecutor’s Office reported that arrests were made on March 26 and 27 (Holy Tuesday and Holy Wednesday – the eve of Maundy Thursday, which is the feast of priests in the Catholic liturgical calendar) against “four former or current Justice Ministry officials,” including Fr. Michal Olszewski as chairman of the “Profeto” foundation (Profeto.pl Foundation – Sercański Sekretariat na rzecz Nowej Evangelizacji, based in Warsaw, KRS 0000494148). “The aforementioned persons were charged with the fact that, acting jointly and in concert, they facilitated the granting of financial support to the “Profeto” foundation, despite the fact that this foundation did not meet the formal and substantive conditions for obtaining a grant. Among other things, the suspects’ actions were alleged to have been to certify untruths in the documentation as to the fulfillment of formal requirements, and, moreover, to inflate the scores for the fulfillment of requirements and substantive conditions.”[4] On March 28, the District Court for Warsaw-Mokotów in Warsaw issued a decision on the application of a preventive measure in the form of a 3-month pre-trial detention. An appeal was filed against this decision[5], but in a decision dated April 30, the Regional Court of Warsaw, IX Criminal Appeals Division, upheld the decision of the District Court, finding the appeal to be unfounded. The court at the same time postponed the drafting of the statement of reasons, which ultimately took place only in the second half of May[6].
On June 4, Rev. Olszewski was charged with two new counts of “money laundering” under Article 299 of the Criminal Code[7], in connection with which, on June 11, a request was made to the Regional Court to extend his pre-trial detention[8]. On June 20, the Regional Court granted the prosecution’s request[9], but the defense team of Rev. Olszewski filed an appeal against the decision. On July 10, Minister of Justice Adam Bodnar issued a statement, according to which Rev. Olszewski and others “acting jointly and in concert facilitated the granting of financial support to the aforementioned foundation, despite the fact that the foundation did not meet the formal and substantive conditions for obtaining a grant. The suspects’ actions were said to have involved, among other things, certifying untruths in the documentation as to the fulfillment of formal requirements, and, moreover, over-scoring the fulfillment of substantive requirements and conditions. The evidence shows that the officials were fully aware that the foundation did not meet the required conditions, and moreover, they acted jointly and in concert with the applicant. These actions resulted in the infliction of damage in the total amount of more than PLN 66 million,” as a result of which “a preventive measure in the form of pre-trial detention was applied against them, the application of which was subsequently extended. The courts applying and extending pre-trial detention against the aforementioned suspects indicated that there was a high probability that the suspects had committed the crimes they were charged with and, moreover, there was a real threat of severe punishment and a real fear of unlawfully influencing the course of the proceedings.”[10]
On July 31, the Court of Appeals in Warsaw decided to shorten the detention period[11]. It was not until October 24 that the Court of Appeals upheld the complaint against the Regional Court’s order[12], and the very next day Rev. Michal Olszewski, along with two Ministry of Justice officials Ursula Dubejko and Karolina Kucharska[13], left the detention center[14]. On November 15, the prosecutor excluded from the investigation into irregularities at the Justice Fund material related to Rev. Olszewski and 8 other suspects[15]. On December 9, the prosecutor of the National Prosecutor’s Office, Piotr Wozniak, announced that an indictment would not be prepared until “late January/early February”[16] [2025].
On July 1, the portal wPolityce.pl published extensive excerpts from a letter by Rev. Michal Olszewski, written while in custody. Its contents show the clergyman, during the course of his arrest and the period of pre-trial detention, which lasted more than half a year, was subject to a whole series of violations of the criminal procedure[17]. On September 6, 2024, an amicus curiae opinion in this case was filed by the Ordo Iuris Institute[18]. Meanwhile, it was not until two and a half months later, on September 16, that the Warsaw-Mokotów District Prosecutor’s Office opened an investigation for exceeding powers and failing to fulfill duties by using psychological violence against Father Olszewski and improper handling of an arrested person and then an detainee, aimed at deliberately tormenting him[19].
2. Violation of Article 245 § 1 of the Code of Criminal Procedure
An excerpt from Fr. Olszewski’s letter of July 1 reads: “Men in balaclavas rushed in and ran up the stairs to the attic, I sat up on my bed, was handcuffed with my hands behind my back, after which an ABW officer (I think he was in charge of the operation) identified himself, showed me an arrest warrant, and then placed a white A4 sheet of paper titled ’rights of a detainee’ on my lap.” One of the points was “immediate contact (from the content, I understood my direct contact) with an attorney.” When I wanted to call a lawyer, I was told that the commanding officer would do so, not me,” the clergyman reported. After an argument, I refused to sign the “rights” and pointed to my phone, which contained the number for Attorney Christopher Wąsowski. The officer in charge (that’s what I’ll call him) searched my phone and found the number. He called and informed my attorney that I had been detained. In answer to my attorney’s question: “Where?”, he replied: ’In the Małopolska region’ and then hung up.”
Whereas, according to Article 245 § 1 of the Code of Criminal Procedure[20], “the arrested person, upon his demand, shall be given the opportunity to contact a lawyer by any means available, and also to talk directly with the latter. The person who made the arrest may reserve the right to be present when such a conversation takes place.” The Decree on the Internal Security Agency (Agencja Bezpieczeństwa Wewnętrznego – ABW)[21] also stipulates that an officer of the Internal Security Agency shall, immediately after apprehending a person, inform the arrested person of his or her rights, in particular by giving him or her a written instruction on the rights of the arrested person in criminal proceedings, conforming to the model specified pursuant to Article 244 § 5 of the Code of Criminal Procedure, and shall, at the request of the apprehended person, take steps to realize his or her rights referred to in item 1.
In turn, the doctrine argues that: “Contact by a detained suspect under a reasonable suspicion of having committed a crime with a lawyer is crucial to ensuring the right to effective defense throughout criminal proceedings. Information obtained at the preliminary stage of criminal proceedings, i.e. even before charges are filed, can be crucial to the final determination of the detainee’s case.”[22] The Supreme Court also states, following another commentary, that “immediate contact with a lawyer should be made possible as soon after detention as is, technically, feasible.”[23] Thus, it appears that Rev. Olszewski’s right to direct contact with his attorney was violated in the case described and unlawfully restricted to indirect contact.
3. Violation of Article 11 of the Law on Direct Coercive Measures
According to Article 25(1) of the Act on the Internal Security Agency (ABW)[24], an ABW officer may use direct coercive measures – including handcuffs, as referred to in Article 12(1)(2) of the Law on Direct Coercive Measures [25] – or use these measures, only in the cases referred to in Article 11(1)-(6) and (8)-(14) of that law. These cases are necessary:
to enforce the legally required behavior in accordance with the authorized order;
to repel a direct, unlawful attack on the life, health or freedom of the authorized person or another person;
to counteract actions aimed directly at an attack on the life, health or freedom of the authorized person or another person;
to counteract violations of public order or security;
to prevent a direct attack on areas, facilities or equipment protected by the authorized person;
to protect order or security in areas or facilities protected by the authorized;
to counter the destruction of property;
to ensure the safety of the convoy or lead;
to capture a person, thwart his escape or pursue that person;
to detain a person, thwart his escape or pursue that person;
to overcome passive resistance;
to overcome active resistance;
to counteract acts intended to cause self-harm.
The doctrine stresses that “for assessing the proportionality of the use of handcuffs, the basic principle is the principle of adequacy (proportionality) of the use of direct coercive measures [referred to in Article 6 (1) of the Law on Direct Coercive Measures], and the principle of minimal harm [referred to in Article 7 (1-4) of that same Law].”[26] Meanwhile, none of the communications concerning Rev. Olszewski’s case indicated that by his behavior he fulfilled any of the prerequisites provided for in the aforementioned Article 11 of the Law. Adam Bodnar himself in 2021, while still Commissioner for Human Rights, pointed out that when using direct coercive measures, including handcuffs, “three, basic principles for their use – subsidiarity, proportionality and minimization of harm – must be met.”[27] In doing so, he cited his earlier position from 2020, according to which “the findings made by the staff of the National Mechanism for the Prevention of Torture (Krajowy Mechanizm Prewencji Tortur – KMPT) during visits to police places of detention indicate, however, that the principles discussed above are not observed in practice,” and “in the vast majority of cases, by fastening handcuffs behind the detainee’s back, the nature of the use of this measure is no longer preventive.”[28] Thus, the handcuffing of Father Olszewski with his hands behind his back should also be considered unlawful as violating the rules on the use of direct coercion.
4. Violation of the prohibition of torture and inhuman treatment guaranteed by the Polish Constitution and conventions
Rev. Olszewski also wrote in his letter: “On the way I asked if I could use the toilet at a rest area. I heard that in a moment we would pull over at a gas station. I asked that it be at a rest area, since there are no people there, and I saw what joy the officers (especially the female officer) had at what had been going on since the morning in the media. So I realized that the operation is also for media effect and on a large scale. I wanted to avoid people. Unfortunately, my request was not granted. The convoy entered the Orlen […] gas station with emergency sirens sounding. I was led in handcuffs to the station toilet, and after leaving the toilet, the ABW officers ordered hot dogs for themselves, while I stood handcuffed in the middle of the station store. People were taking pictures of me and of officers wearing balaclavas. […] From 6 a.m., I remained in handcuffs all day (even when going to the toilet). My handcuffs were not removed, even for a moment. I heard that at this time of day there is neither dinner nor water. I begged for water and received half a bottle of tap water, which was brought in in a bottle and left standing in the cell. In the morning, when I asked to be taken to the toilet, I heard: “Pee into that.”
Meanwhile, Article 40 sentence 1 of the Constitution of the Republic of Poland[29] states that “no one may be subjected to torture or cruel, inhuman, or degrading treatment or punishment.” A similar prohibition is also contained in Article 4 of the Charter of Fundamental Rights of the European Union[30], Article 3 of the European Convention on Human Rights[31] and Article 7 of the International Covenant on Civil and Political Rights[32]. An entire separate Convention against Torture is also dedicated to this prohibition[33], which defines torture as “any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession, punishing him for an act he or a third person has committed or is suspected of having committed, or intimidating or coercing him or a third person, or for any reason based on discrimination of any kind, when such pain or suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity.” Article 41(4) of the Polish Constitution also mentions that “anyone deprived of liberty shall be treated in a humane manner.” There is no doubt that the officers’ refusal to allow Father Olszewski normal exercise of basic physiological functions met the hallmarks of inhuman (inhumane) or degrading treatment and should be treated in terms of violations of the Constitution and international agreements binding on Poland.
5. Attempting to question a defense attorney as a witness – violation of Article 178(1) of the Code of Criminal Procedure
As recently as March 26, Adv. Krzysztof Wąsowski, in accordance with Article 73 of the Code of Criminal Procedure, was appointed defense counsel by Father Michał Olszewski and Urszula Dubejko. Article 178(1) of the Code of Criminal Procedure establishes an absolute prohibition that a defense attorney or a lawyer acting under Article 245(1) of the Code, as to the facts of which he became aware while giving legal advice or conducting a case, may not be questioned as a witness. Meanwhile, in the case described above, there were multiple attempts by the investigators to transgress this prohibition. As early as April 11, Adv. Wąsowski received a summons from the Prosecutor’s Office to testify as a witness, which he immediately notified the Dean of the Regional Bar Council and the Chairman of the Supreme Bar Council. On April 19, however, he appeared for questioning, only to remind the prosecutor that in order to question a lawyer as a witness, it is necessary to first issue an order of exemption from professional secrecy, which, however, can only be issued if it is necessary for the good of justice, and such a prerequisite, according to Adv. Wąsowski, did not exist in the present case[34].
The Dean of the Regional Bar Council had already sent a letter to the National Prosecutor’s Office on April 17, thus even before the date of the hearing, in which he unequivocally indicated that summoning Adv. Wąsowski as a witness constitutes an action aimed at violating the professional secrecy of defense counsel[35]. Meanwhile, over the following months, the prosecutor’s office maintained its previous position, culminating in a letter from prosecutor Piotr Wozniak dated October 30, in which he suggested that since Adv. Wąsowski is a witness, not a defense attorney, and “[his] continued representation of the suspects … raises negative procedural consequences for the named suspects.”[36] Adv. Wąsowski stresses that the prosecutor’s office has not been consistent in its actions. Indeed, at the very first procedural action at the National Prosecutor’s Office, Wąsowski was allowed to act as a defense attorney (and not as a witness, who could not have access to the arrest files), and on November 15 he was notified by the National Prosecutor’s Office of a date for access to the pre-trial files, in accordance with Article 321 § 1 of the Code of Criminal Procedure, and such access can also only be obtained by suspects and their defense attorneys, not witnesses[37]. In conclusion, Adam Bodnar’s prosecutors are probably aware of the internal contradiction of their actions and the fact that in attempting to violate, directly or indirectly, the absolute prohibition of evidence under Article 178(1) of the Code of Criminal Procedure, they are ostentatiously breaking the law.
6. Summary
The actions carried out against Rev. Michal Olszewski by Adam Bodnar’s prosecutors and by law enforcement officers subordinate to both Minister of Justice Adam Bodnar and Minister of the Interior and Administration Marcin Kierwiński (until May 13, 2024, he was the minister to whom the ABW is subordinate) violated a number of guarantees set forth in the provisions of applicable laws – the Constitution, the Code of Criminal Procedure, the Law on Direct Coercive Measures, the Law on the Internal Security Agency (ABW), the EU Charter of Fundamental Rights, the European Convention on Human Rights, the International Covenant on Civil and Political Rights and the Convention against Torture. Regardless of what will be eventually included in the indictment, the abuses carried out against Father Olszewski and his defense attorney clearly indicate that prosecutors do not care about obtaining reliable results, but rather about maintaining a psychological intimidating effect against all those involved in the Justice Fund until 2023.
Nikodem Bernaciak
[1] Information on the establishment of a team to investigate irregularities in the Justice Fund, 30/01/2024, https://www.gov.pl/web/prokuratura-krajowa/informacja-o-powolaniu-zespolu-ds-zbadania-nieprawidlowosci-w-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[2] Information on activities in the investigation of irregularities in the Justice Fund, 26/03/2024, https://www.gov.pl/web/prokuratura-krajowa/informacja-o-czynnosciach-w-sledztwie-dotyczacym-nieprawidlowosci-w-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[3] Law of June 6, 1997. – Criminal Code, consolidated text: OJ 2024, item 17.
[4] Information on the charges presented in the investigation of the Justice Fund], 27/03/2024, https://www.gov.pl/web/prokuratura-krajowa/informacja-o-zarzutach-przedstawionych-w-sledztwie-dotyczacym-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[5] Information on progress in the Justice Fund investigation, 09/04/2024, https://www.gov.pl/web/prokuratura-krajowa/informacja-o-toku-sledztwa-dotyczacego-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[6] Information on the decisions of the Regional Court in Warsaw on irregularities in the Justice Fund, 22/05/2024, https://www.gov.pl/web/prokuratura-krajowa/informacja-o-postanowieniach-sadu-okregowego-w-warszawie-w-sprawie-nieprawidlowosci-w-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[7] Information on supplemental charges against Michał O. in the investigation into irregularities in the Justice Fund, 05/06/2024, https://www.gov.pl/web/prokuratura-krajowa/informacja-o-uzupelnieniu-zarzutow-michalowi-o-w-sledztwie-dotyczacym-nieprawidlowosci-w-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[8] New charges in investigation into irregularities in the Justice Fund, 11/06/2024, https://www.gov.pl/web/prokuratura-krajowa/nowe-zarzuty-w-sledztwie-dotyczacym-nieprawidlowosci-w-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[9] S. Białach, Afera w Funduszu Sprawiedliwości. Justice Fund scandal. Court decision on the arrest of Father Michał Olszewski, 20/06/2024, https://wiadomosci.onet.pl/kraj/afera-w-funduszu-sprawiedliwosci-decyzja-sadu-w-sprawie-aresztu-ks-michala/hcxdnqy (accessed: 09/12/2024).
[10] Statement by the Minister of Justice on disinformation regarding the clarification of the Justice Fund scandal, 10/07/2024, https://www.gov.pl/web/sprawiedliwosc/oswiadczenie-ministra-sprawiedliwosci-w-sprawie-dezinformacji-dotyczacej-wyjasniania-afery-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[11] Sąd skrócił areszt dla ks. Michała Olszewskiego [Court shortens the detention of Rev. Michał Olszewski], 31/07/2024, https://www.pap.pl/aktualnosci/sad-skrocil-areszt-dla-ks-michala-olszewskiego-0 (accessed: 09/12/2024).
[12] Rev. Olszewski may be conditionally. Declarations have been made about paying his bail, 24/10/2024, https://www.pap.pl/aktualnosci/ks-olszewski-moze-warunkowo-wyjsc-z-aresztu-sa-deklaracje-wplaty-kaucji (accessed: 09/12/2024).
[13] The full names of all three suspects are being used publicly by their defense attorney, Adv. Krzysztof Wąsowski, which allows us to presume that they consented to their publication in accordance with Article 13(2) of the Press Law of January 26, 1984 (consolidated text: OJ 2018 item 1914). Cf. 20/11/2024, https://x.com/KaW1944/status/1859140213311779318 (accessed: 09/12/2024).
[14] Rev. Olszewski and two female officials, suspects in the investigation into the Justice Fund case, released from custody, 25/10/2024, https://www.pap.pl/aktualnosci/ks-olszewski-oraz-dwie-urzedniczki-podejrzani-w-sledztwie-dot-funduszu-sprawiedliwosci (accessed: 09/12/2024).
[15] Information on the exclusion from the investigation into irregularities in the Justice Fund of materials relating to 9 suspects, 21/11/2024, https://www.gov.pl/web/prokuratura-krajowa/informacja-o-wylaczeniu-ze-sledztwa-dotyczacego-nieprawidlowosci-w-funduszu-sprawiedliwosci-materialow-w- regarding-9-suspects (accessed: 09/12/2024).
[16] Prosecutor’s office preparing an indictment in the Justice Fund case, 09/12/2024, https://wiadomosci.wp.pl/prokuratura-przygotowuje-akt-oskarzenia-ws-funduszu-sprawiedliwosci-7101448205810304a (accessed: 09/12/2024).
[17] Threats, taunts, blasphemies from fellow inmates. WE DISCLOSE the entire letter from Fr. Olszewski! “Today you will not go home”, 01/07/2024, https://wpolityce.pl/polityka/697371-ujawniamy-list-ks-olszewskiego-grozbybluzgi-wspolwiezniow (accessed: 09/12/2024).
[18] Fr. Olszewski’s trial continues. Ordo Iuris files an amicus brief, 11/09/2024, https://en.ordoiuris.pl/civil-liberties/fr-olszewskis-trial-continues-ordo-iuris-files-amicus-brief (accessed: 09/12/2024).
[19] Warsaw Mokotów District Prosecutor’s Office in Warsaw has opened an investigation into the abuse of power and failure to comply with obligations to the detriment of Michał O., 16/09/2024, https://www.gov.pl/web/po-warszawa/prokuratura-rejonowa-warszawa-mokotow-w-warszawie-wszczela-sledztwo-w-sprawie-przekroczenia-uprawnien-i-niedopelnienia-obowiazkow-na-szkode-michala-o (accessed: 09/12/2024).
[20] Law of June 6, 1997 – Code of Criminal Procedure, consolidated text: OJ 2024, item 37.
[21] Decree of the Council of Ministers of January 7, 2020 on conducting and documenting certain activities by officers of the Internal Security Agency, OJ 2020 item 64.
[22] K. T. Boratyńska, art. 245 [in:] Code of Criminal Procedure. Commentary, ed. A. Sakowicz, Warsaw 2016, p. 601.
[23] Decision of the Supreme Court of October 13, 2011, III KK 64/11, https://www.sn.pl/sites/orzecznictwo/Orzeczenia1/III KK 64-11.pdf (accessed: 09/12/2024).
[24] Law of May 24, 2002 on the Internal Security Agency and the Intelligence Agency, consolidated text: OJ 2024, item 812.
[25] Law of May 24, 2013 on direct coercive measures and firearms, consolidated text: OJ 2024, item 383.
[26] Police use of the right kind of handcuffs in connection with the detention of a person, 2021, https://sip.lex.pl/komentarze-i-publikacje/komentarze-praktyczne/uzycie-przez-policje-wlasciwego-rodzaju-kajdanek-w-470154840 (accessed: 09/12/2024).
[27] Provide greater protection against torture in Poland. CHR asks the Speaker of the Senate to change the law], 30/06/2021, https://bip.brpo.gov.pl/pl/content/zapewnic-wieksza-ochrone-przed-torturami-w-polsce-rpo-prosi-marszalka-senatu-o-zmiane-prawa (accessed: 09/12/2024).
[28] “Handcuffs are not a convenience for the police.” The CHR writes to the Ministry of the Interior about their abuse in convoys and police stations, 22/01/2020, https://bip.brpo.gov.pl/pl/content/kajdanki-nie-ulatwienie-dla-policji-o-ich-naduzywaniu-w-konwojach-i-na-komisariatach-rpo (accessed: 09/12/2024).
[29] Constitution of the Republic of Poland of April 2, 1997, OJ 1997 No. 78, item 483, as amended.
[30] Charter of Fundamental Rights of the European Union, (OJ C 326, 2012, p. 396.
[31] Convention for the Protection of Human Rights and Fundamental Freedoms drawn up in Rome on November 4, 1950, subsequently amended by Protocols Nos. 3, 5 and 8 and supplemented by Protocol No. 2, OJ 1993 No. 61, item 284.
[32] International Covenant on Civil and Political Rights opened for signature in New York on December 19, 1966, OJ 1977 no. 38 item 167.
[33] Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, adopted by the United Nations General Assembly on December 10, 1984, OJ 1989 No. 63 item 378.
[34] B. Aleksowska, Lawyer forced to testify as a witness. “Attorney-client privilege used to be sacrosanct, now it is trampled under foot”, 23/08/2024, https://konfrontacja.com.pl/panorama/adwokat-przymuszony-do-zeznan-jako-swiadek-tajemnica-adwokacka-i-obroncza-byla-swietoscia-dzis-jest-deptana (accessed: 09/12/2024).
[35] B. Aleksowska, The Bar Association reacts to material published by “Konfrontacja” on the case of Adv. Wąsowski. “Prosecutor’s office violates professional secrecy of defense counsel, regulatory changes needed.” 29/08/2024, https://konfrontacja.com.pl/panorama/adwokatura-reaguje-na-material-konfrontacji-o-sprawie-mec-wasowskiego-prokuratura-lamie-tajemnice-obroncza-niezbedne-sa-zmiany-w-przepisach (accessed: 09/12/2024).
[36] W. Biedroń, REVEALED. Bodnar’s people want to get rid of Wąsowski! Strong response from Rev. Olszewski’s defense attorney!, 04/11/2024, https://wpolityce.pl/polityka/711954-ujawniamy-bodnarowcy-chca-pozbawic-ks-olszewskiego-obrony (accessed: 09/12/2024).
[37] K. Wąsowski, https://x.com/KaW1944/status/1859140213311779318 (accessed: 09/12/2024).
