Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, Plaintiff Robert A. Neinast hereby provides the following initial disclosure:

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 one who goes barefoot nearly continuously with knowledge of any hazards regularly encountered, and as a visitor to the Columbus Metropolitan Library and other government and public facilities while barefoot:

Gregory V. Morgan
160 MacAndrews Way
Columbus, OH 43004
614-866-0225

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:

Plaintiff will attach such documents to Plaintiff's Motion for Summary Judgment, and Plaintiff's Memorandum in Opposition to Defendants' Motion for Summary Judgment.

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:

Plaintiff's request for damages is based on the deprivation of the fundamental constitutional rights of free speech, due process, and equal protection.

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:

None.

I hereby certify that a copy of the foregoing was served, by regular U.S. mail, upon Philomena M. Dane and Johnathan E. Sullivan, Attorneys for Defendants, Squire, Sanders & Dempsey, L.L.P., 1300 Huntington Center, 41 South High Street, Columbus, OH, 43215, this 20th day of August, 2001.