REQUEST NO. 9: Admit that the organization's original Article X was changed
completely by Defendants' filing with the Secretary of State dated July 29, 1993.
REQUEST NO. 10: Admit that the organization's original Article XI was
changed completely by Defendants' filing with the Secretary of State dated July 29,
REQUEST NO. 11: Admit that the organization's original Articles did not contain
a numbered Article identified as Article XII.
REQUEST NO. 12: Admit that the organization's first Article XII was that Article
XII as added by the Defendants' filing with the Secretary of State dated July 29, 1993.
REQUEST NO. 13: Admit that the organization's original Articles did not
contain a numbered Article identified as Article XIII.
REQUEST NO. 14: Admit that the organization's first Article XIII was that
Article XIII as added by the Defendants' filing with the Secretary of State dated July 29,
REQUEST NO. 15: Admit that the organization's original Articles did not
contain a numbered Article identified as Article XIV.
REQUEST NO. 16: Admit that the organization's first Article XIV was that
Article XIV as added by the Defendants' filing with the Secretary of State dated July 29,
REQUEST NO. 17: Admit that the organization's original Articles did not
contain a numbered Article identified as Article XV.
REQUEST NO. 18: Admit that the organization's first Article XV was that Article
XV as added by the Defendants' filing with the Secretary of State dated July 29, 1993.
REQUEST NO. 19: Admit that all changes filed with the Secretary of State dated
July 29, 1993 were signed and certified to be true to the State of Minnesota under oath
and with penalty of perjury for false statements.
REQUEST NO. 20: Admit that all changes filed with the Secretary of State dated
July 29, 1993 were signed and certified to be the actions taken by voting members of
the organization at a meeting held on July 1, 1993.
REQUEST NO. 21: Admit that all changes filed with the Secretary of State dated
July 29, 1993 were false except the change recorded to Article I.
REQUEST NO. 22: Admit that all changes filed with the Secretary of State dated
July 29, 1993 were signed and certified by one or more trustees and directors,
signatories, that were unaware of the true nature and exact contents of the filing.
REQUEST NO. 23: Admit that all changes filed with the Secretary of State dated
July 29, 1993 were signed and certified by one or more trustees and directors,
signatories, based only upon the faith and belief that Defendant William N. Matthews
would not lie to them or present them with false information.
REQUEST NO. 24: Admit that absolutely no notice was given to the members
for the changes filed with the Secretary of State dated July 29, 1993 with the sole
exception of notice for a name change to Article I.
REQUEST NO. 25: Admit that absolutely no resolution was presented to the
members for voting on concerning the changes filed with the Secretary of State dated
July 29, 1993 with the sole exception of the resolution for a name change to Article I.
REQUEST NO. 26: Admit that Defendants knew the true and exact nature of
the entire contents of the changes filed with the Secretary of State dated July 29, 1993.
REQUEST NO. 27: Admit that Defendants worked to keep secret the entire
contents of the changes filed with the Secretary of State dated July 29, 1993 and that
none of the general voting members were cognizant or aware of the actual changes filed
REQUEST NO. 28: Admit that absolutely no resolutions were presented to the
general members for voting on concerning the changes filed with the Secretary of State
REQUEST NO. 29: Admit that absolutely no resolution was presented to the
general members for voting on concerning the changes filed to Article V with the
Secretary of State dated November 16, 1994.
REQUEST NO. 30: Admit that absolutely no resolution was presented to the
members for voting on concerning the changes filed to Article IX with the Secretary of
State dated November 16, 1994.
REQUEST NO. 31: Admit that absolutely no resolution was presented to the
members for voting on concerning the changes filed to Article XII with the Secretary of
State dated November 16, 1994.
