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STATE OF MINNESOTA

DISTRICT COURT

COUNTY OF SHERBURNE

TENTH JUDICIAL DISTRICT

__________________________________________________Court File No. ___________

Edward G. Palmer

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Plaintiff

vs.

PLAINTIFFS' FIRST SET OF

REQUESTS FOR ADMISSIONS

William N. Matthews
Solid Rock Church, Inc.
Defendants

______________________________________________________________________________

TO:

Terrence J. Fleming and William F. Stute, Attorneys for Defendants

Lindquist & Vennum P.L.L.P., 4200 IDS Center, 80 South Eight Street,

Minneapolis, Minnesota 55404-2205.

PLEASE TAKE NOTICEthat, pursuant to Rule 36.01 of the Minnesota Rules

of Civil Procedure, you are requested and required to furnish answers to the following

Requests for Admissions to Edward G. Palmer ("Plaintiff") within thirty (30) days from

the date of service. The answer shall specifically deny the matter or set forth in detail the

reasons why the Defendants cannot truthfully admit or deny the matter.

DEFINITIONS AND INSTRUCTIONS

1. These admission requests should be answered in accordance with the

Definitions and Instructions set forth in Plaintiffs' First Set of Interrogatories to

Defendants.

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2. These requests for admissions are deemed to be continuing. If defendants,

defendants' attorneys or defendants' agents obtain any other information which would

add to, modify, or qualify your responses supplied herein, you are directed, pursuant to

Minn. R. Civ. P. 26.05, to give timely notice of such information and furnish the same to

Plaintiff without delay.

3. You are required to answer these Requests for Admission by either stating that

you Admit or Deny the statement. Defendants may not give lack of information or

knowledge as a reason for failure to admit or deny unless Defendants states that a

reasonable inquiry has been made and that the information known or readily obtainable

by Defendants is insufficient to enable the party to admit or deny.

4. Any matter admitted pursuant to this rule is conclusively established unless the

Court on motion permits withdrawal or amendment of the admission. Any admission

made by Defendants is for the purpose of the pending action only and is not an

admission by Defendants for any other purpose nor may it be used against Defendants

in any other proceeding. See Minn. R. Civ. P. 36.02.

5. This set of Request for Admissions deal exclusively with documents on file

with the Secretary of State or internal documents currently only in the possession of the

Defendants. Therefore, Plaintiff has attached no other documents to this request for

admissions.

6. Organization. The term "organization" herein shall be construed to mean

Solid Rock Church, Inc. and its predecessor the Elk River Assembly of God Church as

organized under Minnesota Chapter 317, the Non-Profit Corporation Act.

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7. General members or members.The term "general members" or "members"

used herein shall be construed to mean all members at large and is not to be limited to a

single member or a member of the board or an officer. These terms refer specifically to

the entire or collective voting membership of Solid Rock Church.

ADMISSION REQUESTS