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STATE OF MINNESOTA

DISTRICT COURT

COUNTY OF SHERBURNE

TENTH JUDICIAL DISTRICT

__________________________________________________Court File No. C4-99-1250

Edward G. Palmer

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Plaintiff

vs.

PLAINTIFFS' ANSWER TO

DEFENDANTS FIRST SET OF REQUEST

FOR PRODUCTION OF DOCUMENTS

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 this response is Plaintiffs' Answer made pursuant

to Minnesota Civil Procedure Rule 34.02, which states: "A party who produces

documents for inspection shall produce them as they are kept in the usual course of

business at the time of the request or, at the option of the producing party, shall

organize them to correspond with the categories in the request."

DEFENDANTS' DOCUMENT REQUESTS & PLAINTIFFS' ANSWERS

REQUEST NO. 1:All documents that you contend support, or that refer or relate

to, your claim that Defendants committed fraud upon you.

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ANSWER NO. 1:All documents related to this REQUEST are located at either:

A) On the Internet at http://www.james417.org; or, B) Plaintiffs' office at 16820 Highway

10, Suite 130, Elk River, Minnesota 55330.

Documents located on the Internet at Plaintiffs' web site may be freely inspected

and copied at any time 24 hours a day by defendants.

Documents located at Plaintiffs' office may be inspected and copied at the

convenience of the Defendants during normal office hours of 8 a.m. to 5 p.m. Monday

through Friday except during the dates of August 30 through September 3, 1999 when

these documents will be available between the hours of 8 a.m. to 1 p.m. Documents will

be unavailable on September 6-7 due to Plaintiffs' State Fair schedule.

Defendants are instructed to notify Plaintiff in advance of the date and time they

wish to inspect and copy documents so Plaintiff can arrange his schedule accordingly.

Plaintiff maintains a contemporaneous diary and log of his life for the 24 hours of

each day and has conducted this practice for the last 15-20 years in anticipation of

potential litigation. Plaintiff claims work-product privilege to all such material and the

entries on all dates exclusive of the actual dates involved for the meetings that

Defendants' claim to have held in the filings made to the Minnesota Secretary of State.

Plaintiff has certain work-product or attorney-client privileged communications,

which may include written letters, email letters, computer files, audio-tape or video-tape

records with one or more of the following entities: the Minnesota Attorney General, the

Sherburne County Attorney, the Sherburne County Sheriff, the City of Elk River Police

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Chief; the Internal Revenue Service; the Elk River Star News and, former or current

members of Solid Rock Church.

REQUEST NO. 2:All documents that you contend support, or that refer or relate

to, your claim that Defendants fraudulently induced you to transfer 545,000 shares of

common stock in Attic Technology, Inc., into the name of the Rock Solid Church.

ANSWER NO. 2:Plaintiff has no documents that relate to the transfer of

common stock into the name of the Rock Solid Church.

REQUEST NO. 3:All documents that refer, relate, or reflect on the transfer of any

shares of common stock in Attic Technology, Inc., from you or Attic Technology, Inc. to

Defendants.

ANSWER NO. 3:Plaintiffs' answer is the same as ANSWER No. 1.

REQUEST NO. 4:All documents that refer, relate, or reflect on any incorporation

filings made by Defendants with the Minnesota Secretary of State.

ANSWER NO. 4:Plaintiffs' answer is the same as ANSWER No. 1.