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C. COMPUTATION OF DAMAGES

Plaintiff has economic and non-economic damages, including pain and suffering,
emotional and psychological injuries, and possible past and future wage loss claims. General
damages are a matter for the unique province of the jury. Past and future wage loss will be
explained and supported by expert testimony.

D. INSURANCE AGREEMENTS

This category is not applicable to Plaintiff.

_ 99tte
DATED this 7 ' day of December, 2005.

GORDON, THOMAS, HONEYWELL,
MALANCA, PETERSON & DAHEIM LLP

By MNjesiile finely
Michael T. Pfau, WSBA No. 24649
mpfau@gth-law.com
Michelle A. Menely, WSBA No. 28353
mmmenely@gth-law.com
Attorneys for Plaintiff

PLAINTIFF'S INITIAL DISCLOSURES - 5 of 6 LAW OFFICES

156318 GORDON, THOMAS, HONEYWELL, MALANCA,

PETERSON & DAHEIM LLP.
1201 PACIFIC AVENUE, SUITE 2100
POST OFFICE BOX 1157
TACOMA, WASHINGTON 98401-1157.
(253) 620-6500 - FACSIMILE (253) 620.6565,



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11. Stuart Greenberg, Ph.D.
1217 24" Ave. E., Ste. 220
Seattle, WA 98102

It is believed that Dr. Greenberg has knowledge relating to the effect Fr.
Toulouse's had an certain victims, has knowledge of his communications with
Fr. Stephen Sundberg, S.J. relating to the nature and extent of the defendant's
knowledge of Fr. Toulouse's activities.

Plaintiff reserves the right to identify additional individuals or parties with
discoverable information, including expert witnesses.

Plaintiff further reserves the right to call at trial any and all witnesses identified by the
Defendant or which may be identified at a later date by Plaintiff during discovery in this

matter.

B. DOCUMENTS

1. Plaintiff identifies the personnel file maintained by defendant for Fr. Michael
Toulouse and produced by defendant to plaintiff's counsel on July 6, 2005. In the interest of
maintaining confidentiality, and to avoid duplicative production of documents, plaintiff does
not attach the documents hereto. If defendant's desire an additional copy of the file, it will be
produced.

2. Clinical records maintained by Dr. Bill Lennon. These documents were
produced to defendant on July 6, 2005. In the interest of maintaining confidentiality, and to
avoid duplicative production of documents, plaintiff does not attach the documents hereto. If
defendant's desire an additional copy of the file, it will be produced.

3. J.C.'s medical records, to be obtained.

Plaintiff reserves the right to disclose additional relevant documents as discovery

progresses.
PLAINTIFF'S INITIAL DISCLOSURES - 4 of 6 LAW OFFICES
156318 GORDON, THOMAS, HONEYWELL, MALANCA,

PETERSON & DAHEIM LLP
1201 PACIFIC AVENUE, SUITE 2100
POST OFFICE BOX 1157
TACOMA, WASHINGTON 98401-1157
(258) 820-6500 - FACSIMILE (253) 620-8565



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CERTIFICATE OF SERVICE

THIS IS TO CERTIFY that on this 7 Bay of December, 2005, I did serve true and

correct copies of the foregoing via ECF procedures by directing delivery to and addressed to

the following:

Counsel for Defendant:

Thomas V. Dulcich, Esq.

Mario J. Madden, Esq.

SCHWABE, WILLIAMSON & WYATT, P.C.
U.S. Bank Centre

1420 Fifth Ave., Suite 3010

Seattle, WA 98101
con

Tanya Garbell,
Legal Assistant to Michael T. Pfau

PLAINTIFF'S INITIAL DISCLOSURES - 6 of 6 LAWOFFICES

156318

GORDON, THOMAS, HONEYWELL, MALANCA,

PETERSON & DAHEIM LLP.
1201 PACIFIC AVENUE, SUITE 2100
POST OFFICE BOX 1157,
TACOMA, WASHINGTON 98401-1157
(253) 620-6500 - FACSIMILE (253) 620.6565,



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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

AT SEATTLE
J.C., individually,
Plaintiff, NO. 2:05-CV-01662-JLR
vs. PLAINTIFF'S INITIAL DISCLOSURES

PURSUANT TO FRCP 26(a)(1)

SOCIETY OF JESUS, OREGON PROVINCE,
an Oregon Corporation,

Defendant.

A. IDENTITY OF INDIVIDUALS WITH DISCOVERABLE INFORMATION

1. Plaintiff, J.C.
c/o GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM, LLP
2100 One Union Square
Seattle, WA 98101

Plaintiff J.C. is aware of, among other things, the nature of the abuse he
suffered, along with the damages has sustained as a result of that abuse.

2. Plaintiff, J.C.'s wife -- Susan Cook
c/o GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM, LLP
2100 One Union Square
Seattle, WA 98101

Susan Cook is aware of, among other things, her knowledge and observations
of J.C.'s damages, including emotional difficulties.

PLAINTIFF'S INITIAL DISCLOSURES - | of 6 LAW OFFICES

156318 GORDON, THOMAS, HONEYWELL, MALANCA,
PETERSON & DAHEIM LLP
1201 PACIFIC AVENUE, SUITE 2100
POST OFFICE BOX 1157
‘TACOMA, WASHINGTON 98401-1157
(253) 620-8500 - FACSIMILE (253) 620-8565



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PLAINTIFF'S INITIAL DISCLOSURES - 2 of 6

156318

Plaintiff, J.C.'s mother — Elizabeth Cook
7612 37" St., West, Unit 1E

University Place, WA 98466
253.566.6197

Elizabeth Cook is aware of, among other things, her observations and
interactions with Fr. Toulouse, and her knowledge and observations of J.C.'s
damages, including emotional difficulties.

Plaintiff, J.C.'s brother — Dale R. Cook
3805 90 th Ave Ct. East

Puyallup, WA 98371

253.312.0767

Dale Cook is aware of, among other things, his observations of and
interactions with Fr. Toulouse and has knowledge of J.C.'s damages, including
emotional difficulties.

Plaintiff, J.C.'s cousin — Thomas Helm
Auburn, WA
253.709.9849

Thomas Helm is aware of, among other things, his observations of and
interactions with Fr. Toulouse and has knowledge of J.C.'s damages, including
emotional difficulties.

Cindy Versherin

2739 72TM Avenue SE
Mercer Island, WA 98040
206.232.6732

Ms. Versherin has knowledge of, among other things, Fr. Toulouse
victimization of children.

Dr. Bill Lennon

Bellevue Community Services, Inc.
2281 116" Ave. NE, Suite 6
Bellevue, WA 98004-3037
425.454.0616

Dr. Lennon is J.C.'s counselor. He is aware of the effect the abuse had an
J.C.'s life.

LaworFices
GORDON, THOMAS, HONEYWELL, MALANCA,
PETERSON & DAHEIM LLP
1201 PACIFIC AVENUE, SUITE 2100,

POST OFFICE BOX 1157
TACOMA, WASHINGTON 98401-1187
(253) 620-6560 - FACSIMILE (259) 620-6565,



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10.

Members, employees and/or agents of the Society of Jesus, Oregon
Province and/or of Seattle University and/or of the Archdiocese of Seattle,
including, but not limited to,

Fr. Thomas P. Martin, S.J.,

Fr. Patrick J. Ford, S.J.,

Christine Taylor, Chancellor, Archdiocese of Seattle,

Fr. John D. Whitney, S.J.,

Joyce M. Cox, BVM,

Jessie Dye,

Kathryn Johnson,

Michael A. Tyrrell, S.J.,

Rev. Stephen Sundborg, S.J.,

Robert B. Grimm, S.J.,

Most Rev. Alex Brunet, D.D.,

Archbishop Connolly,

Fr. Earl LaRiveiere,

Fr. Joseph Perri, S.J.,

Rev. John Fitterer,

Fr. Louis Gaffney, S.J.,

V. Rev. George L. Thomas, Chancellor, Archdioceses of Seattle

Len Beil,

Bill Sullivan

These individuals have knowledge which includes, but is not limited to,
identities of the victims of Fr. Michael Toulouse, knowledge that Fr. Michael
Toulouse was a perpetrator of childhood sexual abuse or potential danger to
children. Moreover, these witnesses are believed to have knowledge about the
Oregon Province of the Society of Jesus’ policies and practices regarding the
hiring, monitoring and supervision of its priests and their response to
allegations of childhood abuse.

Other victims of childhood sexual abuse — names currently unknown.

Dominick Toulouse, M.D. nephew of Fr. Michael Toulouse
4011 Talbot Road South, Suite 460

Renton, WA 98055

425.271.5020

It is believed that Dominick Toulouse has knowledge of the nature and extent
of Fr. Toulouse abuse of children.

PLAINTIFF'S INITIAL DISCLOSURES - 3 of 6 LAWOFFICES

156318

GORDON, THOMAS, HONEYWELL, MALANCA,
PETERSON & DAHEIM LLP.
1201 PACIFIC AVENUE, SUITE 2100,
POST OFFICE BOX 1157
TACOMA, WASHINGTON 98401-1157
(253) 620-8560 - FACSIMILE (259) 620-6565,