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STATE OF MINNESOTA

DISTRICT COURT

COUNTY OF SHERBURNE

TENTH JUDICIAL DISTRICT

__________________________________________________Court File No. ___________

Edward G. Palmer

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Plaintiff

vs.

PLAINTIFFS' SECOND SET

OF INTERROGATORIES

William N. Matthews
Solid Rock Church, Inc.
Defendants

______________________________________________________________________________

TO:

Terrence J. Fleming and William F. Stute, Attorneys for Defendants

Lindquist & Vennum P.L.L.P., 4200 IDS Center, 80 South Eight Street,

Minneapolis, Minnesota 55404-2205.

PLEASE TAKE NOTICEthat, pursuant to Rule 33.01(b) of the Minnesota

Rules of Civil Procedure, you are requested and required to furnish answers to the

following Interrogatories to Edward G. Palmer ("Plaintiff") within thirty (30) days from

the date of service. These Interrogatories are continuing and require supplemental

answers if additional responsive information is obtained. See Minn. R. Civ. P. 26.05.

DEFINITIONS AND INSTRUCTIONS

1. You and your.The terms "you" and "your" means and refer to both of the

defendants, their agents, employees, representatives, or attorneys, and all other persons

or entities acting on their behalf.

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2. Defendants. The term "Defendants" means and refers to Defendants William N.

Matthews and Solid Rock Church, Inc., and includes any of its current or former agents,

employees, representatives, attorneys, officers, directors, divisions, and departments.

3. Plaintiff. The term Plaintiff means Edward G. Palmer and includes any of his

current or former agents, representatives and attorneys.

4. Communication.The term "communication" means the transmittal of

information (in the form of facts, ideas, inquiries or otherwise).

5. Document. The term "document" means all items referred to in Rule 34.01 of

the Minnesota Rules of Civil Procedure, and any and all other written, printed, typed, or

other graphic or photographic material of any nature, any audio or video recordings,

computer data, as well as disks or other devices storing such data, and other data

compilations from which information can be obtained, and translated, if necessary, by

you through detection devices into reasonably usable form. A draft or non-identical

copy is a separate document within the meaning of this term.

6. Identify (With Respect to Persons).When referring to a person, "to identify"

means to give, to the extent known, the person's full name, present or last known

address, and when referring to a natural person, additionally the present or last known

place of employment. Once a person has been identified in accordance with this

subparagraph, only the name of that person need be listed in response to subsequent

discovery requesting the identification of that person.

7.Identify (With Respect to Documents).When referring to a document, "to

identify" means to give, to the extent known, the (i) type of document; (ii) general

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subject matter; (iii) date of the document; and (iv) author(s), addressee(s) and

recipient(s).

8. Identify (With Respect to Communications).When referring to

communications, "to identify" means to give, to the extent known, the (i) names,

addresses and last known places of employment of the participants to the

communication; (ii) the subject matter and precise content of the communication; (iii) the

location(s) of the communication; (iv) the mode of communication (e.g. written, by

telephone, meeting, etc.); and (v) the date of the communication.

9.Identify (With Respect to a Fact, Circumstance, or Event).When referring

to a fact, circumstance or event, "to identify" means to give, to the extent known, the (i)

time period or date of such fact, circumstance, or event; (ii) the place at which the fact,

circumstance, or event occurred (if any); (iii) the identity of all persons with personal

knowledge of the fact, circumstance, or event; (iv) a complete description of the fact,

circumstance, or event; (v) the identity of all documents relating to the fact, circumstance

or event.

10. Reflect, relate to, or refer to.The terms "reflect," "relate to," or "refer to"

mean constituting, evidencing, containing, discussing, showing, reflecting, concerning,

relating or referring to in any way, directly or indirectly, and, when used in reference to

the documents, also include documents underlying, supporting, necessary for the

understanding of, now or previously attached or appended to, or used in the preparation

of any document referred to or requested by any interrogatory.

11. Parties.The terms "plaintiff" and "defendants," as well as a party's full or

abbreviated name or a pronoun referring to a party, means the party and, where