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INTERROGATORY NO. 2:Identify each person whom you may call as an expert

witness at the time of trial and, with respect to each such person, state the following:

(1)The subject matter upon which the person is expected to testify;

(2)The substance of the facts and opinions to which the person is expected to

testify;

(3)The person's education and background identifying any and all articles,

books, other writings by this person; and

(4)A detailed and specific summary of the grounds for each opinion.

ANSWER NO. 2:Plaintiff has no current plans to call any expert witnesses.

INTERROGATORY NO. 3:Identify every person from Solid Rock Church, Inc.,

with whom you have communicated regarding the issues raised by your Complaint

and/or Defendants' Answer, identify each communication and identify all documents

referring, reflecting or relating to such communications.

ANSWER NO. 3:Plaintiff has not directly communicated with anyone at Solid

Rock Church concerning the above with the sole exception of William N. Matthews.

However, Plaintiff has made all of this information available to the public at Plaintiff's

web site and has received at least one email from a person who identified himself or

herself as a current member of Solid Rock Church.

Plaintiff was not able to identify the individual who sent the email. The email

address, date sent and content are considered privileged as attorney work product.

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INTERROGATORY NO. 4:Identify every person with whom you, including

your attorneys and agents, have communicated regarding the issues raised in your

Complaint and/or Defendants' Answer, identify each such communication and identify

all documents referring, reflecting or relating to such communications.

ANSWER NO. 4:Plaintiff has a small group of advisors that is communicated

with on a regular basis. The identities of these individuals and the nature and content of

all communications are privileged information and are covered by attorney-client or

attorney work-product.

Plaintiff has had communications with the Minnesota Attorney General; the

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

Chief; the Internal Revenue Service; the Elk River Star News; and, former members of

Solid Rock Church. The nature and content of these communications are privileged

information and are covered by attorney-client or attorney work-product.

Other than the above, Plaintiff has not had any communications with specific

individuals. However, Plaintiff has made all of this information readily available to the

public at Plaintiffs' web site located at http://www.james417.org.

INTERROGATORY NO. 5:Describe in all possible detail all the facts upon which

you base your allegation in paragraphs 10 and 25 of the Complaint that you were

fraudulently induced to transfer shares of common stock in Attic Technology, Inc. into

the name of Solid Rock Church.

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ANSWER NO. 5:Plaintiff has been a corporate officer for over 25 years and

has full knowledge of Minnesota Corporate law both at Minn. Stat. § 302A and at

Minn. Stat. § 317.

As CEO of corporations, Plaintiff has functioned as a General Counsel and has

managed by-laws and articles for over 25 years.

In the above capacity, Plaintiff has changed by-laws and articles in accordance

with the corporation's charter documents including the provisions set forth in Articles

and the provisions set forth in By-Laws.

In the above capacity, Plaintiff has changed by-laws and articles in accordance

with the provisions as set forth in Minnesota Corporate Law and in compliance with

those laws.

Plaintiff advised defendants during 1994-1995 that they might be in violation of

Minn. Stat. §317 by not supplying proper notice of business meetings to members.

Defendants told Plaintiff at the time of the above advisement that everything was

under proper control and led Plaintiff to believe that Defendants were in full compliance

with the provisions of the corporation's By-Laws.

Defendants told Plaintiff at the time of the above advisement that everything was

under proper control and led Plaintiff to believe that Defendants were in full compliance

with the provisions of the corporations Article's.