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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' SECOND 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 and the additional Definitions provided in Plaintiffs' First Set of Requests for

Admissions.

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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 second set of Requests for Admissions concerns Plaintiffs' Exhibits 1-5

which are attached hereto and the Articles of Incorporation filings at the Minnesota

Secretary of State's Office.

6. To avoid duplicate request for admission numbers and the confusion inherent

therein, the numbering of the attached requests for admissions are continued from the

number forty-four (44), which was the ending number in Plaintiffs' First Set of Requests

for Admissions. Therefore, the first number in this Second Request for Admissions is the

number forty-five (45).

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ADMISSION REQUESTS

REQUEST NO. 45: Admit that the resolution attached hereto as Plaintiffs'

Exhibit No. 1 is an exact copy of the resolution used by Defendants to change the name

of the organization from the Elk River Assembly of God Church to the name of Solid

Rock Church at the meeting held on July 1, 1993.

REQUEST NO. 46: Admit that the resolution shown as Exhibit No. 1 is the

absolute only resolution that was presented to the members of the organization for

consideration at the business meeting held on July 1, 1993.

REQUEST NO. 47: Admit that Plaintiffs' Exhibit No. 2 is an exact copy of

Defendants' Meeting Notice supplied for the organization's business meeting scheduled

for September 29, 1994.

REQUEST NO. 48: Admit that Defendants dated the notice shown as Exhibit

No. 2 (meeting notice) September 20, 1994 which was only nine (9) days prior to the

scheduled business meeting held on September 29, 1994.

REQUEST NO. 49: Admit that the notice shown as Exhibit No. 2 specifies that

changes will be made to "Article XII - Property" of the Articles of Incorporation.

REQUEST NO. 50: Admit that the notice shown as Exhibit No. 2 identifies no

other changes to the Articles of Incorporation.

REQUEST NO. 51: Admit that Defendants filed a change with the Minnesota

Secretary of State under oath to Article V as a result of the September 29, 1994 business

meeting.