:Well I haven't looked at this article in awhile, but now that you mention it there does appear to be the problem with the lede, in particular that sentence and the one right next to it. 
 :The first sentence: The actions of the UPA resulted in over 35,000 Polish civilian casualties in Volhynia - it's a bit POV to give just the lower bound on the casualty estimates here. In fact, this is not just any lower bound but a lower bound found in a single source, which may not be representative. If you look at the table we were working on, it's clear that most other lower bounds are at least 40k. Also, the upper bound should be given as well. Again, based on the table, the sentence should be changed to "between 40k and 70k Polish civilian casualties". If we are going to refer to "regions combined" then it should be "60k to 90k". 
 :The second sentence: Ukrainian casualties at the hands of Poles during the conflict range from 2,000 to 20,000 in Volhynia,[14][15] and 20,000 for the two regions combined. I'm ok with giving 20k for "regions combined" as that's at least feasible though most definitely an upper bound. However, it should not say 20k for Volhynia alone. As far as I can tell this is, again, a single source, which is probably confusing Volhynia with "regions combined". Even the Snyder number of 10k might be talking about both regions. This would be like including some of the Polish casualty estimates that go up as high as 150k. 
 :Personally in this I would go with the most reliable sources and leave the "outliers" out of it. That would mean Snyder and Motyka. 
 :So yes, there is POV here but perhaps not in the way you think. 
 :As to the "massacre" name - this is the term used in reliable sources. Are there reliable English language sources which talk about "massacres of Ukrainians in Volhynia and Eastern Galicia" out there?