Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, Defendants Board of Trustees of the Columbus Metropolitan Library ("the Library"), Larry D. Black and Vonzell Johnson (collectively, "Defendants") hereby provide the following initial disclosures:

A. the name and, if known, the address and telephone number of each individual likely to have discoverable information that the disclosing party may use to support its claims or defenses, unless solely for impeachment, identifying the subjects of the information.

DISCLOSURE:

As to the Library's reasons for adopting the Eviction Procedure, his authority to adopt regulations for the operation of the Library, and the allegations contained in Plaintiff's Amended Complaint.

As to the events alleged in Plaintiff's Amended Complaint.

As to the events alleged in Plaintiff's Amended Complaint.

As to the events alleged in Plaintiff's Amended Complaint.

As to the Board of Trustees' delegation of authority to Mr. Black, its knowledge of the Eviction Procedure, and individual members' knowledge of the events alleged in Plaintiff's Amended Complaint.

B. A copy of, or a description by category and location of, all documents, data compilations, and tangible things that are in the possession, custody, or control of the party and that the disclosing party may use to support its claims or defenses, unless solely for impeachment.

DISCLOSURE:

Defendants have attached all documents described in the rule as exhibits to their motion for summary judgment, filed and served on August 2, 2001.

C. A computation of any category of damages claimed by the disclosing party, making available for inspection and copying as under Rule 34 the documents or other evidentiary material, not privileged or protected from disclosure, on which such computation is based, including materials bearing on the nature and extent of injuries suffered.

DISCLOSURE:

Defendants do not currently claim any damages in relation to this action.

D. for inspection and copying as under Rule 34 any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in the action or to indemnify or reimburse for payments made to satisfy the judgment.

DISCLOSURE:

After commencement of discovery, the applicable agreement between the Columbus Metropolitan Library and its insurance carrier will be made available for copying and inspection, as required, at the offices of Squire, Sanders & Dempsey, L.L.P., 41 South High Street, Columbus, Ohio 43215

The undersigned hereby certifies that a copy of the foregoing Defendants' Rule 26(a)(1) Initial Disclosures was served by regular U.S. mail, postage prepaid, upon Robert A. Neinast, Plaintiff, 8617 Ashford Lane, Pickerington, Ohio 43147, this 9th day of August, 2001.