REQUEST NO. 32: Admit that absolutely no resolution was presented to the
members for voting on concerning the changes filed to Article XIV with the Secretary of
State dated November 16, 1994.
REQUEST NO. 33: Admit that absolutely no resolutions were presented to the
members for voting on concerning the changes filed with the Secretary of State dated
REQUEST NO. 34: Admit that absolutely no resolutions were presented to the
members for voting on concerning the changes filed with the Secretary of State dated
REQUEST NO. 35: Admit that Article IV filed with the Secretary of State dated
November 14, 1995 took away the Plaintiffs' voting rights.
REQUEST NO. 36: Admit that Plaintiff was present for the entire business
meeting of July 1, 1993 and testified in favor of the name change to Solid Rock Church.
REQUEST NO. 37: Admit that Plaintiff was present for all business meetings of
the members from July 1993 through November 1996.
REQUEST NO. 38: Admit that the original By-Laws required advance notice of
the entire content of any change to Articles or By-Laws be provided to the members of
REQUEST NO. 39: Admit that this requirement of the By-Laws for advance
notice of changes to Articles is adopted as Article XV of the Articles filed with the
Secretary of State dated July 29, 1993.
REQUEST NO. 40: Admit that Article XV of the Articles filed with the Secretary
of State dated July 29, 1993 required a two-thirds vote of members attending a meeting
to adopt any changes to the Articles providing further that a quorum be present.
REQUEST NO. 41: Admit that Article XV of the Articles filed with the Secretary
of State dated July 29, 1993 requires a posting of the amendment for four consecutive
Sundays in a conspicuous place prior to any meeting that is called to adopt any changes
REQUEST NO. 42: Admit that Article XV of the Articles filed with the Secretary
of State dated July 29, 1993 requires "due notice" of the amendment for four
consecutive Sundays in a conspicuous place prior to any meeting that is called to adopt
any changes to the Articles.
REQUEST NO. 43: Admit that Article XV of the Articles filed with the Secretary
of State dated July 29, 1993 requires a "quorum" at any meeting that is called to adopt
any changes to the Articles.
REQUEST NO. 44: Admit that the collective changes to all Articles operated in
concert to deprive the members of the organization of their property and other rights as
guaranteed under Minnesota Law at Chapter 317.
_____________________________________
Edward G. Palmer, Plaintiff
15548 95th Circle NE
Otsego, Minnesota 55330
(612) 441-3440
(612) 441-7174 Fax
