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INTERROGATORY NO. 11:Identify every fact that you contend supports your

allegation contained in paragraph 21 of the Complaint that the officers and directors of

Solid Rock Church violated the basic standards of conduct set forth in Minn. Stat.

§317A.

ANSWER NO. 11:The officers and directors signed false filings with the

Secretary of State which violate the standard of conduct set forth at 317A.361 for

officers and 317A.251 for directors. Other facts may be present in the documents

Plaintiff has made available to Defendants.

INTERROGATORY NO. 12:Identify each fact that you contend supports your

allegation contained in paragraph 23 of the Complaint that Defendants usurped

Plaintiff's control and took away his ability to exercise voting rights.

ANSWER NO. 12:Plaintiff had voting rights. After the Defendants false filings,

Plaintiff had no voting rights and the Articles of Incorporation now state specifically

that only the board of trustees has voting rights. The fact that no members voted on this

was a usurpation of all member-voting rights including those of the Plaintiff. Other facts

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

INTERROGATORY NO. 13:Identify each fact upon which you contend

supports your claim contained in paragraph 24 of the Complaint that Defendants

illegally converted Plaintiff's 545,000 shares of stock from an organization the Plaintiff

had full voting rights in to an organization that Plaintiff had no voting rights in.

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ANSWER NO. 13:The falsified article changes filed with the Secretary of State;

the total ignoring of all member rights in the articles; the total ignoring of all member

rights in the bylaws; the total ignoring of all member rights in Minn. Stat. §317A; the

lack of regard the officers had for member rights in making false changes; the lack of

regard the directors had for member rights in making false changes; the fact that material

information was consistently withheld by Defendants; the sheer fabrication of non-

existent meetings for purposes of filing false documents; and, other facts that may be

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

INTERROGATORY NO. 14:Identify each fact that you contend supports your

allegation contained in paragraph 26 of the Complaint that Defendants conducted

fraudulent business activities and this induced Plaintiff into giving them cash.

ANSWER NO. 14:Defendants presented information to the members which

were inconsistent with Defendants behind the scenes manipulation of articles; the

working of the article changes constitute fraud by swindle when viewed in their totality;

the withholding of material information of which, had the Plaintiff known, would have

allowed Plaintiff to make different choices that were consistent with Plaintiff's beliefs;

the constant cult-like programming that Defendants used to solicit contributions from

Plaintiff; Defendant William N. Matthews' hour-long cult-like programming on giving at

most meetings he held led Plaintiff to believe he was giving to an organization that had

honesty and integrity; Defendants lack of honesty and integrity is exemplified by the

false statements filed under oath with the Secretary of State; and, other facts may be

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

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INTERROGATORY NO. 15:Identify each fact that you contend supports your

allegation contained in paragraph 27 of the Complaint that Defendant William N.

Matthews willfully and with well thought planning, withheld material facts and other

important information with intent to work a swindle and fraud upon you.

ANSWER NO. 15:Defendants withheld financial information; Defendants

withheld information about the lawsuit started by the Assembly of God Minnesota

District Office; Defendants withheld information about the actual article changes being

made at various meetings; by making unauthorized changes, Defendants were dishonest

and demonstrated a lack of integrity; Defendants actions were opposite and inconsistent

with what Defendants were constantly programming their members to think and believe;

Defendants fabricated meetings where none occurred; Defendants withheld material

facts about the true nature of an affiliation with the AFCM in that Defendants never

advised the members of the organization that they would be required to give up their

voting rights.

By taking the above actions, Defendants clearly worked a fraud upon all of the

members of the organization including the Plaintiff. By examining all of the article

changes from 1993 through 1997, it is simply obvious from a common sense standpoint

that a swindle has occurred because all of the false filings appear to be actions that are

linear in nature and directed toward the singular goal of limiting ownership in the

corporation to Defendant William N. Matthews and a few others as yet unknown.

Defendants' actions worked constantly to thin-out the voting membership block of the

corporation. Defendant regularly asked anyone who questioned him to immediately

leave the organization stating they were no longer welcomed. Other facts may be

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