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ANSWER NO. 6:Plaintiff was an eyewitness at all of the actual meetings;

Plaintiff kept a contemporaneous diary of his life including notes from all business

meetings; Plaintiff diligently attends all business meetings in those organization he

participates in and Solid Rock Church was not an exception to this practice; Plaintiffs

records indicate that several meetings were simply manufactured, fictitious and non-

existent; article changes lead to only one ending and that is the disenfranchisement of

the organization's members and the limited ownership of the organization's assets by

Defendant William N. Matthews and a few others yet unidentified; non-voting members

have no ownership in Solid Rock Church; other facts may exist in the documents

Plaintiff has made available to Defendants.

INTERROGATORY NO. 7:Identify all facts upon which you base your

allegation contained in paragraph 22 of the Complaint that all changes made to the

Articles by Defendants, except the name change, are illegal under Minn. Stat. § 317A.

ANSWER NO. 7:Plaintiff was an eyewitness; only one resolution was

presented and discussed; the organization's articles and by-laws called for full disclosure

of the contents of any article changes prior to the meeting; nothing was disclosed to the

members except the name change; the members voted on nothing but a name change;

Defendants lacked authority to make changes without member approval; there was no

approval of anything except a name change; and, Plaintiff kept detailed records of the

meeting in question which includes the exact resolution to change the corporation's

name and a contemporaneous comment on the actual outcome and of Plaintiffs' peculiar

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participation in the discussion and debate over the name change. Other facts may be

present in the documents that Plaintiff has made available to Defendants.

INTERROGATORY NO. 8:Identify each fact upon which you base you

allegation contained in paragraph 13 of the Complaint that Defendants made

unauthorized changes to virtually every Article and that Defendants illegally created

and adopted a new charter.

ANSWER NO. 8:Plaintiff was present at the meeting; Plaintiff examined before

and after articles and found changes made to virtually all articles; Defendants lacked

authority to change even a single word in any Article without first obtaining member

approval by supplying proper notice and then obtaining a majority vote at a meeting

which had a quorum; Defendants simply filed these changes without any member

knowledge; other facts may be present within the documents that Plaintiff has made

available to Defendants.

INTERROGATORY NO. 9:Identify all facts upon which you base your

allegation contained in paragraph 19 of the Complaint that proper notice of all article

changes was not obtained from the members of the corporation.

ANSWER NO. 9:Plaintiff does not understand the question as presented.

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INTERROGATORY NO. 10:Identify each fact upon which you base your

allegation contained in paragraph 20 of the Complaint that Defendants enacted false

changes to the articles of incorporation, and that by doing so Defendants violated Minn.

Stat. §317A.

ANSWER NO. 10:Defendants violated the standard of conduct cited at

317A.361 for officers as false filings were not in the best interest of the corporation;

Defendants violated the standard of conduct cited at 317A.251 for directors as false

filings were not in the best interests of the corporation; Defendants violated 317A.433

Subd 4 which states that notice requirements of "special" meetings must contain a

statement of the purposes of the meeting; Defendants violated 317A.435 by not giving a

notice with the minimum required time as specified in the articles and bylaws;

Defendants violated 317A.111 Subd 3, which specifically states that all members were

entitled to vote and have equal rights and preferences in all matters; nothing contrary to

317A.111 Subd 3 were contained in the corporation's articles or by-laws; other facts may

be present in the documents Plaintiff has made available to Defendants.

Defendants conduct was inconsistent with and totally ignored the requirements

of Minnesota Statute 317A, the Non-Profit Corporation Act. The behavior of the

officers and directors were a sham and the actions taken by the Defendants were actions

resembling that of a proprietorship and not the actions of a corporation, its officers and

directors.

Defendants "elected" to be governed by Minn. Stat. §317A and were therefore

obligated to conform to the requirements of Minnesota's Non-Profit Corporation Law.