Roger and Sharon Wortmann, et al. - Page 3

                                         -3-                                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the accompanying exhibits are                  
          incorporated by this reference.  Petitioners Roger and Sharon               
          Wortmann resided in Hartington, Nebraska, at the time they filed            
          their petition.  Petitioners Michael J. and Leslie A. Cain                  
          resided in Bloomfield, Nebraska, at the time they filed their               
          petition.  Petitioners Steven L. and Nancy E. Archbold resided in           
          Bloomfield, Nebraska, at the time they filed their petition.                
          Petitioners William J. and Janice L. Hesse resided in Yankton,              
          South Dakota, at the time they filed their petition.                        
          The Monastery                                                               
               In the late 1970s, Father Clifford Stevens, a Catholic                 
          priest, was serving as the pastor for a church in Neligh,                   
          Nebraska.  Father Stevens had dreamed of building a monastery and           
          looked in many places for the right piece of land on which to               
          build the monastery.                                                        
               In the early 1980s, Father Stevens found a 240-acre parcel             
          of land about 10 miles from Neligh, Nebraska, near Oakdale,                 
          Nebraska, that he considered perfect for the monastery.  Father             
          Stevens received permission from the Archbishop of Omaha                    
          (Archbishop) to build a monastery on the land and arranged for              
          incorporating a nonprofit organization, called the Monks of                 
          Tintern, Inc. (Monks Nonprofit), to obtain the land.  The Monks             
          Nonprofit obtained the land and constructed a barn-shaped                   
          monastery and a chapel.                                                     





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