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Court File No. ___________
PLAINTIFFS' FIRST SET OF REQUEST
FOR PRODUCTION OF DOCUMENTS
William N. Matthews
Solid Rock Church, Inc.
Defendants
______________________________________________________________________________
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 you are required to produce and permit Plaintiff,
Edward G. Palmer ("Plaintiff") to inspect and copy documents referred to herein.
Defendants are required to make these documents available for inspection and copying
within thirty (30) days from the date of service of this request at a time and place
mutually agreed upon by Plaintiff and counsel for the Defendants. In lieu of this,
Defendants may comply with this request by mailing true and accurate copies of all
documents requested to Plaintiff within thirty days of this request.
DEFINITIONS AND INSTRUCTIONS
1. These document requests should be answered in accordance with the
Definitions and Instructions set forth in Plaintiffs' First Set of Interrogatories to
2. These requests for production of documents 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 produce the requested documents in their original form,
within their original file jacket or other enclosure and, to the extent possible, identify in a
meaningful way the paragraph and subparagraph of the requests appearing below to
which the documents respond. In answering these requests for production, if privilege is
alleged as to any information or documents, or if any request is otherwise not answered
in full after the exercise of due diligence to secure complete information, state the
specific grounds for not answering in full and answer said request for production to the
extent to which no privilege is claimed or to the extent to which information is available,
fully identify the information or documents for which the privilege is asserted, and
specify the privilege (e.g., work product, attorney client).
4. You are requested to identify and list all documents called for by these
requests but withheld from production on the grounds of attorney-client privilege, work
product protection or any other basis, and to specify in writing the grounds for non-
production. All such documents should be numbered, held separately and retained
intact pending a ruling by the Court on the claimed privilege. Each document shall be
identified by author(s) and recipient(s), date, number of pages, attachments and
appendices, general description of the nature and subject matter of the document, title, if
any, nature of the privilege claimed and the present custodian.
5. If any document herein requested was formerly in the possession, custody or
control of defendants, its agents, representatives, employees, officers, directors or
attorneys, and has been lost or destroyed, you are requested to submit in lieu of each
document a written statement which:
(a) Describes in detail the nature of the document and its contents;
(b) Identifies the person who prepared or authored the document and, if
applicable, the person to who the document was sent;
(c) Specifies the date on which the document was prepared or transmitted or
both; and
(d) Specifies, if possible, the date on which the document was lost or destroyed,
and, if destroyed, the conditions of or reasons for such destruction and the
persons requesting and performing the destruction.
REQUEST NO. 1: All documents relating to the Articles of Incorporation of
Solid Rock Church including the original Articles of Incorporation of the Elk River
Assembly of God Church and all changes subsequently made thereto.
REQUEST NO. 2: All documents relating to the By-Laws of Solid Rock Church
including the original By-Laws of the Elk River Assembly of God Church and all
changes subsequently made thereto.
REQUEST NO. 3: All documents related to actions initiated by the members of
the Board of Directors (Trustees) or Officers of Solid Rock Church concerning making
changes to the Articles of Incorporation or the By-laws of said organization.
REQUEST NO. 4: All documents related to actions initiated by other members of
Solid Rock Church, voting or non-voting, concerning making changes to the Articles of
Incorporation or the By-laws of said organization.
