COURT OF COMMON PLEAS
FRANKLIN COUNTY, OH


Robert A. Neinast
Plaintiff,
v.
Board of Trustees of the Columbus Metropolitan Library, et. al
Defendants.

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Case No. 04CVH-06-6341

Judge Miller




DEFENDANTS' INITIAL DISCLOSURE OF ALL WITNESSES



Pursuant to Local Rule 43 and the Clerk's Original Case Schedule filed June 17, 2004, Defendants Board of Trustees of the Columbus Metropolitan Library and Patrick Losinski disclose the following witnesses that they may call at the trial of this matter.


LAY WITNESSES
  1. Robert A. Neinast (as if on cross-examination)
    8617 Ashford Lane
    Pickerington, Ohio 43147

    As to facts alleged in Plaintiff's Complaint.

  2. Terry A. Boyd
    Cynthia Hilsheimer
    Jacqueline F. Woods
    Philip C. Johnston
    Charlotte P. Kessler
    Samuel H. Porter
    David C. Swaddling
    Patrick Losinksi
    Robert Johnson
    96 South Grant Avenue
    Columbus, Ohio 43215

    As to the passage of the Library's Patron Code of Conduct.

  3. All witnesses called by Plaintiff, as if upon cross-examination.

Defendants reserve the right to identify additional expert and lay witnesses as discovery proceeds, pursuant to the Civil Rules and the Court's modified case schedule.

  Respectfully submitted,
_______________________
Philomena M. Dane (0044064)
Johnathan E. Sullivan (0072371)
Squire, Sanders & Dempsey L.L.P.
1300 Huntington Center
41 South High Street
Columbus, OH 43215
(614) 365-2700

Attorney for Defendants
Board of Trustees of the Columbus
Metropolitan Library and Patrick A.
Losinski



CERTIFICATE OF SERVICE

I hereby certify that a true and accurate copy of the foregoing Initial Disclosure of All Witnesses was served by regular U.S. mail, postage prepaid, upon Robert A. Neinast, Plaintiff, 8617 Ashford Lane, Pickerington, Ohio 43147, this 4th day of November, 2004.


  /s/   P. L. Dane