REQUEST NO. 52: Admit that Defendants offered no resolution to the members
to change Article V at the September 29, 1994 business meeting.
REQUEST NO. 53: Admit that Defendants filed a change with the Minnesota
Secretary of State under oath to Article IX as a result of the September 29, 1994 business
REQUEST NO. 54: Admit that Defendants offered no resolution to the members
to change Article IX at the September 29, 1994 business meeting.
REQUEST NO. 55: Admit that Defendants filed a change with the Minnesota
Secretary of State under oath to Article XIV as a result of the September 29, 1994
REQUEST NO. 56: Admit that Defendants offered no resolution to the members
to change Article XIV at the September 29, 1994 business meeting.
REQUEST NO. 57: Admit that Plaintiffs' Exhibit No. 3 is an exact copy of the
contents of the meeting notice Defendants supplied the members of the organization for
the July 11, 1995 meeting.
REQUEST NO. 58: Admit that the notice shown as Exhibit No. 3 is dated July 7,
1995 and is only four (4) days from the business meeting held on July 11, 1995.
REQUEST NO. 59: Admit that the notice shown as Exhibit No. 3 states nothing
about proposed changes to the organization's Articles of Incorporation.
REQUEST NO. 60: Admit that the members of the organization whom attended
the July 11, 1995 business meeting of the organization had no resolutions presented to
them to for voting on to change the organization's Articles of Incorporation.
REQUEST NO. 61: Admit that Plaintiffs' Exhibit No. 4 is an exact copy of the
contents of the only resolution that Defendants presented to the members of the
organization at their July 11, 1995 business meeting.
REQUEST NO. 62: Admit that the resolution shown as Exhibit No. 4 specifies at
its heading that it is a resolution to the By-Laws.
REQUEST NO. 63: Admit that the resolution shown as Exhibit No. 4 specifies in
its last clause that a committee will be made up "to present changes in the Constitution
and By-Laws to the congregation at a later date."
REQUEST NO. 64: Admit that resolution shown as Exhibit No. 4 provides no
authority for Defendants to alter the organization's Articles of Incorporation.
REQUEST NO. 65: Admit that the resolution shown as Exhibit No. 4 does not
constitute a vote by the organization's members to give up their voting rights as granted
REQUEST NO. 66: Admit that the resolution shown as Exhibit No. 4 passed by
the following vote: 60 yes, 5 no, and 1 abstention.
REQUEST NO. 67: Admit that members of the organization had no idea that
Defendants intended to use the resolution shown as Exhibit No. 4 as their authority to
alter the organization's Articles of Incorporation.
REQUEST NO. 68: Admit that members of the organization had no idea that
Defendants intended to alter the organization's Articles of Incorporation as a result of
the business meeting held on July 11, 1995.
REQUEST NO. 69: Admit that Plaintiffs' Exhibit No. 5 is an exact copy of the
contents of the resolution that Defendants sent to the Association of Faith Church
Ministries (AFCM) on or about November 7, 1996.
REQUEST NO. 70: Admit that the resolution shown as Exhibit No. 5 states that
a meeting was held on November 7, 1996.
REQUEST NO. 71: Admit that the resolution shown as Exhibit No. 5 was sent
less than ninety (90) days after the members voted to affiliate with the AFCM.
REQUEST NO. 72: Admit that the resolution shown as Exhibit No. 5 represents
the exact opposite instructions of what the members voted for less than ninety (90) days
prior to the date listed thereon.
REQUEST NO. 73: Admit that no meeting of the members occurred on
_____________________________________
Edward G. Palmer, Plaintiff
15548 95th Circle NE
Otsego, Minnesota 55330
(612) 441-3440
(612) 441-7174 Fax
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