REQUEST NO. 17: All documents related to mailings including letters sent to
members of the organization for any purpose including that of group communications.
REQUEST NO. 18: All documents related to mailing lists including a printout of
all databases used to send mailings, solicitations, communications or invitations with the
full name, address and phone number, if available, of everyone on those mailing lists.
Identify all former and current members. Identify all current-voting members. If possible,
identify the dates in which members officially became members and the date in which
they left the organization.
REQUEST NO. 19: All documents related to attendance records including all
usher documents having estimated attendance figures and offering receipts.
REQUEST NO. 20: All bank statements from the period of time from September
1992 through December 1998.
_____________________________________
Edward G. Palmer, Plaintiff
15548 95th Circle NE
Otsego, Minnesota 55330
(612) 441-3440
(612) 441-7174 Fax
