REQUEST NO. 5: All documents related to the Business meeting of Solid Rock
Church that was held on or about July 1, 1993 that resulted in a new filing with the
Minnesota Secretary of State dated July 29, 1993, which altered and changed the
Articles of Incorporation of Solid Rock Church. These business meeting documents
should include the following: a) the meeting notice mailed to members; b) a list of
general church attendees; c) a list of the voting members of the organization; d) a list of
business meeting attendees; e) the business resolutions presented for voting on; f) the
voting outcome of each resolution; g) the meeting agenda; h) the meeting minutes; i)
audio tape records; and, j) a list of the Officers, Directors, and office staff on that date.
REQUEST NO. 6: All documents related to the Business meeting of Solid Rock
Church that was held on or about June 6, 1994 that resulted in a new filing with the
Minnesota Secretary of State dated June 23, 1994, which altered and changed the
Articles of Incorporation of Solid Rock Church. These business meeting documents
should include the following: a) the meeting notice mailed to members; b) a list of
general church attendees; c) a list of the voting members of the organization; d) a list of
business meeting attendees; e) the business resolutions presented for voting on; f) the
voting outcome of each resolution; g) the meeting agenda; h) the meeting minutes; i)
audio tape records; and, j) a list of the Officers, Directors, and office staff on that date.
REQUEST NO. 7: All documents related to the Business meeting of Solid Rock
Church that was held on or about September 29, 1994 that resulted in a new filing with
the Minnesota Secretary of State dated November 16, 1994, which altered and changed
the Articles of Incorporation of Solid Rock Church. These business meeting documents
should include the following: a) the meeting notice mailed to members; b) a list of
general church attendees; c) a list of the voting members of the organization; d) a list of
business meeting attendees; e) the business resolutions presented for voting on; f) the
voting outcome of each resolution; g) the meeting agenda; h) the meeting minutes; i)
audio tape records; and, j) a list of the Officers, Directors, and office staff on that date.
REQUEST NO. 8: All documents related to the Business meeting of Solid Rock
Church that was held on or about July 11, 1995 that resulted in a new filing with the
Minnesota Secretary of State dated November 14, 1995, which altered and changed the
Articles of Incorporation of Solid Rock Church. These business meeting documents
should include the following: a) the meeting notice mailed to members; b) a list of
general church attendees; c) a list of the voting members of the organization; d) a list of
business meeting attendees; e) the business resolutions presented for voting on; f) the
voting outcome of each resolution; g) the meeting agenda; h) the meeting minutes; i)
audio tape records; and, j) a list of the Officers, Directors, and office staff on that date.
REQUEST NO. 9: All documents related to any Business meeting of Solid Rock
Church that was held after July 11, 1995 that resulted in or could result in a new filing
with the Minnesota Secretary of State to further alter and/or change the Articles of
Incorporation of Solid Rock Church. Such business meeting documents should include
the following: a) the meeting notice mailed to members; b) a list of general church
attendees; c) a list of the voting members of the organization; d) a list of business
meeting attendees; e) the business resolutions presented for voting on; f) the voting
outcome of each resolution; g) the meeting agenda; h) the meeting minutes; i) audio tape
records; and, j) a list of the Officers, Directors, and office staff on that date.
REQUEST NO. 10: All documents related to the disaffiliation with the Assembly
of God Ministries, its Minnesota District or National Office by defendants.
REQUEST NO. 11: All documents related to the affiliation and subsequent
disaffiliation with the Association of Faith Church Ministries (AFCM) by defendants.
REQUEST NO. 12: All documents related to real property owned or in the name
of William N. Matthews or Solid Rock Church or in which defendants have a beneficial
interest including documents relating to ownership by joint-tenancy or partnership.
REQUEST NO. 13: All business organizing or incorporating documents related
to any business in which defendants are involved, other than Solid Rock Church. This
includes any business in which defendants are listed as either an incorporator, proprietor,
partner, owner, co-owner, joint-tenant, manager, officer, director, agent or in which
defendants have any beneficial interest in.
REQUEST NO. 14: All documents related to gifts or charitable donations of
property in any form including real property and cash over a value of $500.00 that was
given to or received by either William N. Matthews or Solid Rock Church during the
period of time from September 1992 through December 1998.
REQUEST NO. 15: All documents related to any gift transfers of property in any
form including real property or cash having an aggregate value over $900.00, excluding
normal disbursements resulting from business operating expenses, that were given by
Defendants to any other person or entity during the period of time from September 1992
REQUEST NO. 16: All documents related to any lawsuit in which either of the
defendants has been listed as a plaintiff or as a defendant.
