21. It is a matter of public and Court records that [prior] Pastor James Hoogenboom from
the Elk River Assembly of God Church was charged in misdemeanor disorderly
conduct complaint 71-K9-92-1396 filed on October 20, 1992 by the State of
22. It is a matter of public and Court records that Pastor James Hoogenboom and
business manager Dexter Mapson from the Elk River Assembly of God Church were
named in [a third] civil complaint 71-C3-92-1474 filed on November 5, 1992.
23. It is a matter of public and Court records that the Elk River Assembly of God Church
was named as one of four defendants in civil complaint 71-C4-92-1828 filed by John
X. Doe on December 11, 1992. Said civil suit involved the highly public sex scandal
of former Senior Pastor James L. Hoogenboom.
24. It is a matter of public and Court records that business manager Dexter Mapson from
the Elk River Assembly of God Church was charged in misdemeanor theft complaint
71-KX-93-1174 filed on August 30, 1993.
25. It is a matter of public and Court records that the Defendant Solid Rock Church filed
civil lawsuit 71-C4-94-239 on February 24, 1994 against the former business manager
Dexter Mapson to recover funds allegedly swindled from the non-profit corporation.
Said civil suit was publicly reported by the Elk River Star News as an action taken by
Defendant Solid Rock Church under the Minnesota Fraudulent Conveyance Act.
26. It is within the context of the public sex and theft scandals, criminal complaints and
several civil lawsuits that Defendant William N. Matthews was elected President.
27. Plaintiff attended the non-profit corporation at the time Defendant William N.
Matthews was presented to the members for consideration as its new President.
28. It was clear to Plaintiff and most members, at the time Defendant William N. Matthews
was elected as the new President, that the non-profit corporation Elk River Assembly
of God was in a legal and public relations nightmare.
29. Defendant William N. Matthews was given the task of cleaning up the corporation's
mess. At the center of the corporation's mess was dishonesty and lack of integrity.
30. William N. Matthews had been a credentialed minister with the Assembly of God
since 1984 and had served as Pastor of the Chelsea Christian Fellowship Church in
Chelsea, Michigan, beginning in 1990 until he started with Solid Rock Church.
31. Defendant William N. Matthews emphasized honesty and integrity in the wake of the
two highly public scandals and civil lawsuits. This emphasis had a direct impact on
Plaintiff's state of mind and his feeling that proper corporate actions were underway.
32. Plaintiff's state of mind was concerned with how the corporation was going to clean
up its mess and Plaintiff had just cause to believe that William N. Matthews as an
experienced minister with Assembly of God credentials was trustworthy.
33. The Elk River Assembly of God Church was affiliated with the Minnesota District
Assemblies of God Ministries based in Minneapolis.
34. The Minnesota District Assemblies of God Ministries had contingent property rights
35. Plaintiff had just cause to believe that the Minnesota District Assemblies of God
Ministries exerted some oversight functions concerning both Pastor William N.
Matthews and the non-profit corporation the Elk River Assembly of God Church.
36. Plaintiff began attending the Elk River Assembly of God Church in July 1992.
37. The reason Plaintiff starting attending this non-profit corporation was to assist in the
rebuilding of the corporation, which was publicly soiled and in need of new help.
38. Plaintiff was planning on joining the corporation and attended corporate membership
classes conducted by William N. Matthews during April to June of 1993.
39. Plaintiff's state of mind was concerned about honesty in the wake of the public
scandals and Plaintiff had just cause to believe both Defendants were honest.
40. Plaintiff's state of mind was concerned about integrity in the wake of the public
scandals and Plaintiff had just cause to believe both Defendants had integrity.
41. Plaintiff had just cause to believe he would be joining a congregational church where
the majority ruled and each member had equal voting rights.
42. On July 1, 1993 the members of the Elk River Assembly of God Church assembled to
43. Plaintiff attended the July 1, 1993 meeting and spoke in favor of the new name.
44. One reason specified in the July 1, 1993 name change resolution was to distance the
corporation from the "negative events that transpired in the past."
45. The fourth clause in the name change resolution of July 1, 1993 read "Whereas Our
church is founded on The Solid Rock."
It directly implies integrity and is consistent
with other statements made by the Defendants to "condition" Plaintiff's state of mind.
46. On July 1, 1993 the members of the Elk River Assembly of God Church were only
presented with a name change resolution. No other changes or discussion of other
changes to the articles occurred during this business meeting.
