In accordance with Rule 43 of the Local Rules of Practice of the Franklin County Court of Common Pleas and the Clerk's Original Case Schedule, Plaintiff Robert A. Neinast hereby submits the following as his Initial Joint Disclosure of Witnesses:

• Plaintiff, Robert A. Neinast, 8617 Ashford Lane, Pickerington, OH, 43147, 614-759-1601 — This lay witness has relevant knowledge of using numerous public facilities and public accomodations barefooted, and of the conditions in the Columbus Metropolitan Library relevant to barefooted use. He also has relevant knowledge of the reactions of others to his barefootedness.

• Defendant, Patrick A. Losinksi, Executive Director of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH, 43215, 614-849-1005 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy.

• Terry A. Boyd, President, Board of Trustees of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-645-2275 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy.

• Cynthia A. Hilsheimer, Vice President, Board of Trustees of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-645-2275 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy.

• Jacqueline F. Woods, Secretary, Board of Trustees of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-645-2275 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy.

• Philip C. Johnston, Member, Board of Trustees of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-645-2275 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy.

• Charlotte P. Kessler, Member, Board of Trustees of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-645-2275 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy.

• Samuel H. Porter, Member, Board of Trustees of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-645-2275 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy.

• David C. Swaddling, Member, Board of Trustees of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-645-2275 — This lay witness has relevant knowledge regarding the Library's enactment and enforcement of their barefoot policy, as well as knowledge of the original barefoot policy promulgated by former Executive Director Larry D. Black.

• Larry D. Black, former Executive Director of the Columbus Metropolitan Library, address and telephone number unknown — This lay witness has relevant knowledge of the promulgation of the original barefoot policy.

• Chris Taylor, Special Projects Director of the Columbus Metropolitan Library, 96 S. Grant Ave., Columbus, OH 43215, 614-849-1265 — This lay witness has relevant knowledge of the evictions of Robert Neinast.

• Gregory V. Morgan, [removed for privacy reasons] — This lay witness has relevant knowledge of going barefoot regularly, and of using the CML barefoot.

• Burton Koss, [removed for privacy reasons] — This lay witness has relevant knowledge of going barefoot regularly, including a wide variety of public buildings and public accomodations.

• Morgan Condo, Legal Issues Program Manager for the Columbus Health Department, 240 Parsons Ave., Columbus, OH, 43215, 614-645-6754 — This expert witness will testify that there is no Health Department regulation requiring shoes in public buildings.

• Becky Callender, Director of the Pickerington Public Library, 201 Opportunity Way, Pickerington, OH, 43147 — This lay witness will testify that the Pickerington Public Library has no regulation requiring shoes in that library.

Plaintiff reserves the right to amend his witness list upon reasonable notice to Defendants.

I hereby certify that a copy of the foregoing was served, by regular U.S. mail, postage prepaid 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  4th  day of November, 2004.