applicable, its officers, partners, employees, agents, representatives and attorneys. This
definition is not intended to impose a discovery obligation on any person who is not a
12. Person.
The term "person" is defined as any natural person or business, legal
or governmental entity or association.
13. Concerning.The term "concerning" means relating to, referring to, describing,
evidencing or constituting.
14. All/Each.The terms "all" and "each" shall be construed as all and each.
15. And/Or.The connectives "and" and "or" shall be construed either
disjunctively or conjunctively as necessary to bring within the scope of the discovery
request all responses that might otherwise be construed to be outside of its scope.
16. Singular/Plural and Past/Present Tense.Words in the singular include the
plural, and words in the plural include the singular. "Each" and "any" are both singular
and plural. Words in the past tense include the present, and words in the present tense
include the past. The word "including" should be construed without limitation.
17. Objections.If you deem any of the following interrogatories legally
objectionable, in whole or in part, you shall set forth all grounds for the objection in
sufficient detail to enable plaintiffs and the Court to determine the legal sufficiency of
such objection. If you object in part, you shall fully respond to such part or parts of the
interrogatory to which no objection is made.
18. Gender.Use of any terms denominating gender shall be construed to include
both the masculine and the feminine.
19. Claims of Privilege.If a claim of privilege is asserted concerning any
information sought or any document for which identification is requested, provide the
(a) Identify all communications by stating the participants in the
communication, the date of the communication, and the general subject
matter of the communication.
(b) Identify all documents by identifying the (i) type of document (letter,
memo, and so forth); (ii) general subject matter of the document; (iii)
date of the document; (iv) author(s), addressee(s), and recipient(s);
(c) State the nature of the privilege asserted; and
(d) State in detail the factual and legal basis for the claim of privilege.
20. Organization. The term "organization" herein shall be construed to mean
Solid Rock Church, Inc. and its predecessor the Elk River Assembly of God Church as
organized under Minnesota Chapter 317, the Non-Profit Corporation Act.
21. General members or members.The term "general members" or "members"
used herein shall be construed to mean all members at large and is not to be limited to a
single member or a member of the board or an officer. These terms refer specifically to
the entire or collective voting membership of Solid Rock Church.
22. The following Interrogatories are concerned with Plaintiffs' Exhibits 1-5
attached to Plaintiffs' Second Set of Requests for Admissions. Defendants are instructed
to carefully review those Exhibits. These Interrogatories are numbered sequentially
starting with number 11. Numbers 1-10 are in Plaintiffs' First Set of Interrogatories.
INTERROGATORY NO. 11: Identify every person who has, or who you
believe may have, any knowledge or information relating to the business meeting held
on July 1, 1993 including all who attended said meeting and state the knowledge or
information known or believed to be possessed by each such person.
INTERROGATORY NO. 12: Identify every person who has, or who you
believe may have, any knowledge or information relating to the resolution shown as
Plaintiffs' Exhibit No. 1 and state the knowledge or information known or believed to be
possessed by each such person.
INTERROGATORY NO. 13: Identify every person who has, or who you
believe may have, any knowledge or information relating to the business meeting held
on September 29, 1994 including all who attended said meeting and state the
knowledge or information known or believed to be possessed by each such person.
INTERROGATORY NO. 14: Identify every person who has, or who you
believe may have, any knowledge or information relating to the meeting notice shown
as Plaintiffs' Exhibit No. 2 and state the knowledge or information known or believed to
be possessed by each such person.
INTERROGATORY NO. 15: Identify every person who has, or who you
believe may have, any knowledge or information relating to the business meeting held
on July 11, 1995 including all who attended said meeting and state the knowledge or
information known or believed to be possessed by each such person.
