Terrence J. Fleming, Attorney
William F. Stute, Attorney
Lindquist & Vennum P.L.L.P.
4200 IDS Center
80 South 8thStreet
Minneapolis, Minnesota 55402

August 27, 1999

Re. Edward G. Palmer v.
William N. Matthews and Solid Rock Church, Inc.

Dear Mr. Fleming and Mr. Stute:

Enclosed and served upon you in the above-referenced matter, please find the
following:

1. Plaintiffs' response to Defendants' First Set of Interrogatories; and

2. Plaintiffs' response to Defendants' First Set of Requests for Production of
Documents.

Concerning Defendants' Affirmative Defenses:

1. Plaintiff has stated several claims under which the doctrine of replevin applies and
where the Courts can grant relief.

2. The statute of limitations for commencing action under fraud is stated at Minn.
Stat. § 541.05 (6) and is as follows: "For relief on the ground of fraud, in which
case the case of action shall not be deemed to have accrued until the discovery
by the aggrieved party of the facts constituting the fraud;"Plaintiff discovered
this fraud in April of 1998. The statute of limitations is six years from that date.

3. Plaintiff has made consistent and timely efforts to resolve this issue with
Defendants and the doctrines of "laches" and "bad faith" simply do not apply.

4. The doctrine of "ratification" does not apply since the term itself "implies an intent
to ratify with knowledge as to the things being ratified, including full knowledge
of all material circumstances."See Prather v Colorado Oil and Gas Corp., 542
P.2d 297, 218 Kan. 111.

5. The doctrine of "waiver" does not apply since "to constitute a waiver of a legal
right there must be clear, unequivocal and decisive act of the party with
knowledge of such right and an evident purpose to surrender it."See First
Nationa1 Bank of Milford v Department of Banking Commonwealth of Pa., 286
A.2d. 480.

Edward G. Palmer v.
William N. Matthews and Solid Rock Church, Inc.
August 27, 1999
Page 2 of 2

6. Plaintiff has pled fraud with the requisite particularity in the Complaint.

7. Plaintiff has supplied the missing acknowledgment in accordance with Minn.
Stat. § 549.211 (1).

Plaintiff rejects Defendant's counter offer to settle this suit as being preposterous given
the outrageous fraud that the Defendants have clearly committed.

If Defendants want to assert a First Amendment argument as you suggest, Plaintiff will
find it necessary to file a motion to compel discovery. Plaintiff will also file a motion for
sanctions for a bad faith and frivolous response. That's because virtually nothing within
Plaintiff's Complaint can be construed as an impingement upon any individual or any
organization's ability to freely practice their religious beliefs. Further, nothing within
Plaintiff's Complaint could be construed as the government unreasonably burdening or
encroaching upon the ability of any individual or organization's ability to freely practice
their religious beliefs.

Freedom of religion is not the freedom to commit fraud with impunity. It is also not the
freedom to violate Minnesota corporate law.

Defendants freely elected to incorporate themselves as a Minnesota non-profit
corporation. Defendants freely elected to be governed by Minnesota law at Chapter
317A and freely constructed both Articles and By-Laws to be governed by that law.

Plaintiff believes the Courts will immediately reject such an argument as being of bad
faith, frivolous and non-responsive to Plaintiffs discovery efforts.

If you have any questions or would like to discuss any of the issues, please call me.

Sincerely yours,

Edward G. Palmer
Plaintiff

15548 95th Circle NE
Otsego, Minnesota 55330
(612) 441-3440
(612) 441-7174 Fax