DAVID LANDRUM, Oregon State Bar ID Number 955425

Senior Deputy City Attorney

Email: david.landrum(4ortlandoregon.gov 

DANIEL SIMON, OSB No. 124544

Assistant Deputy City Attorney

Email: dan.simon@portlandoregon.gov

Office of City Attorney .

1221 SW 4th Avenue, Suite 430

Portland, OR 97204

Telephone: (503) 823-4047

Facsimile: (503) 823-3089

Attorneys for Defendants

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

JOSEPH WALSH, 3:15-cv-01666 SI

PLAINTIFF,

DECLARATION OF JOHN J.

v. CHANDLER

BRYANT ENGE, CHARLIE HALES, (In Support of Defendants' Motion for

CITY OF PORTLAND, Summary Judgment)

DEFENDANTS.

I, John J. Chandler, declare as follows:

1. I am employed by G4S Security International as the project manager for security

services provided to the City of Portland for City Hall and the Portland Building. I have held

this position since July 10, 2014.

2. My duties include oversight responsibility for the security contract for G4S Secure

Solutions, Inc., who provide armed and unarmed uniformed security services to the City of

Portland. As part of those duties I act on behalf of Bryant Enge, Bureau Director of Internal

Business Services, who is granted authority and enforcement responsibilities of the "Code of

Conduct for the City of Portland Properties" by the Mayor Charles Hales and Commissioners.

Page 1 — DECLARATION OF JOHN J. CHANDLER

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 21 Filed 10/30/15 Page 1 of 5
3. In my work experience, it is my observation that individuals visiting City offices,

especially City Hall and City Council sessions, can be very disruptive and engage in

inappropriate behavior which can result in exclusions and possibly arrest. The security of the

buildings and its occupants is always the first priority for the security staff.

4. Security officers document the activities which take place in City Hall, the Portland

Building and adjacent rights of way. Activities are not only recorded on video, but through

written reports.

5. I directed all security officers to write incident reports documenting security

concerns and disruptive and/or inappropriate behaviors. (See Report by Wayne Dykes,

01/09/2014, attached as Exhibit A.)

6. I also write incident reports.

7. I am familiar with Mr. Joe Walsh as he is a frequent demonstrator outside City Hall.

He also regularly attends City Council meetings to observe and provide public testimony.

8. Mr. Walsh has a long history of being disruptive and combative while protesting

outside City Hall, inside the building and while attending City Council meetings.

9. Attached to this Declaration as Exhibit A is a true and correct copy of the incident

report written by former Sergeant Wayne Dykes documenting Mr. Walsh's behavior at the

January 9, 2014 City Council meeting.

10. On May 7, 2014, I was contacted by Lisa Frisch on the 1st floor of City Hall. Ms.

Frisch asked that I escort her from the building because of fear of retaliation from Joe Walsh.

11. Attached to this Declaration as Exhibit B is a true and correct copy of the incident

report I wrote on May 7, 2014 documenting Ms. Frisch's concerns.

12. I was present at the May 13, 2015 City Council meeting and observed Mr. Walsh's

behavior. Mayor Hales opened the session with his usual verbal admonishment regarding

appropriate behavior expectations for Council meetings based on the Rules of Conduct for all

City properties. I observed Mr. Walsh in attendance during Mayor'Hales' admonishment on

Page 2 — DECLARATION OF JOHN J. CHANDLER

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 21 Filed 10/30/15 Page 2 of 5
decorum. Following Council's vote to proceed on Agenda Item 485 regarding demolishing the

reservoirs, several individuals in attendance began to shout over the top of Mayor Hales. The

audience employed very loud, boisterous and obnoxious chanting of the words "No" and "Boo."

The chants grew louder and louder. Mayor Hales again admonished the crowd to stop. Since the

audience continued to engage in its disruptive behavior, a recess was called. Joseph Walsh,

Jessie Sponberg and Steven Entwhistle appeared to be directing the disruptive behaviors of the

audience. They were the most vocal. Mr. Walsh rolled up a newspaper, resembling a

megaphone, and repeatedly yelled "No" and "Boo" directly at Mayor Hales. The Mayor and

Commissioners left the chamber. When the session reconvened, Dan Handelman and Constantin

Severe attempted to present testimony on Agenda Item 486, but the crowd, lead by Walsh,

Sponberg and Entwhistle repeated chanting "No," "Boo", and "No Demolition." Mr. Walsh laid

down behind Mr. Severe while he testified and with his "megaphone" continued to yell "No" and

"Boo".

13. Attached to this Declaration as Exhibit C is a true and correct copy of the incident

report I wrote on May 13, 2015 documenting in detail Mr. Walsh's behavior on that date.

14. Mr. Walsh attended the City Council meeting on July 8, 2015. After exiting the

chambers on that date, Mr. Walsh approached Josh Alpert (Mayor's Chief of Staff) who was

standing in the Atrium area outside of City Council chambers. Walsh yelled at Alpert causing a

disruption in City Hall.

15. Mr. Walsh's disruptive behavior during the July 8, 2015 City Council meeting

resulted in him being excluded from City Hall for 60 days.

16. Attached to this Declaration as Exhibit D is a true and correct copy of the

supplemental incident report I wrote documenting Mr. Walsh's behavior toward Mr. Alpert on

July 9, 2015.

17. I personally served a Formal Exclusion letter on Mr. Walsh on July 15, 2015 at

approximately 9:05 a.m. while he was in City Hall. I informed Mr. Walsh that he was formally

Page 3 — DECLARATION OF JOHN J. CHANDLER

PORTLAND CITY ATTORNEYS OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 21 Filed 10/30/15 Page 3 of 5
excluded from City Hall, the entire building and all the property surrounding the building for 60

days. Mr. Walsh took the exclusion letter from my hands and ripped the letter up into several

small pieces and strewed the remnants of the letter onto the floor in front of City Hall Council

Chambers. Mr. Walsh then raised his voice to a boisterous high pitch and made combative

verbal statements regarding my actions. Mr. Walsh then left the building and immediately

walked to the public sidewalk in front of City Hall and began yelling and pounding an unknown

instrument on a metal surface for two hours.

18. On July 15, 2015 at approximately 10:10 a.m., in violation of his Exclusion from

City Hall, Mr. Walsh entered City Hall through its main entrance on SW 4th Avenue and

proceeded to the men's restroom on the 1St floor. I contacted Portland Police Officer Mike

Bledsoe and informed him of Mr. Walsh's violation of the Exclusion. I entered the men's

restroom accompanied by Officer Mike Bledsoe and advised Mr. Walsh that I was having him

arrested for trespassing. Mr. Walsh became extremely boisterous and made accusations.

19. Mr. Walsh has been excluded from City Hall on two previous occasions and is fully

aware of its limitations on his presence in the building.

20. Attached to this Declaration as Exhibit E is a true and correct copy of the incident

report I wrote on July 15, 2015 documenting in detail my interaction with Mr. Walsh on that

date.

21. I make this declaration in support of Defendants' Motion for Summary Judgment..

I hereby declare that the above statement is true to the best of my knowledge and

belief, and that I understand it is made for use as evidence in court and is subject to penalty

for perjury.

DATED: October 1.10 , 2015.

John J. Chandler

Page 4 — DECLARATION OF JOHN J. CHANDLER

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 21 Filed 10/30/15 Page 4 of 5
CERTIFICATE OF SERVICE

I hereby certify that I served the foregoing DECLARATION OF JOHN J. CHANDLER on:

Joseph F. Walsh

7348 SE Division Street

Portland, OR 97206

Plaintiff-Pro Se

30

on October $, 2015, by causing a full, true and correct copy thereof, addressed to the lastknown address (or fax number) of said attorney, to be sent by the following method(s):

E by mail in a sealed envelope, with postage paid, and deposited with the U.S. Postal

Service in Portland, Oregon.

El by hand delivery.

by email pursuant to LR 5-2(b).

El by facsimile transmission.

El by email.

Page 1 — CERTIFICATE OF SERVICE

AS WA

DAVID LANDRUM, OSB #955425

Senior Deputy City Attorney

DANIEL SIMON, OSB No. 124544

Assistant Deputy City Attorney

Telephone: (503) 823-4047

Attorneys for Defendants

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 21 Filed 10/30/15 Page 5 of 5