Michelle Barton Smigel, P.C., OSB No. 045530

michelle. smigel@millernash. com

Michael Porter, P.C., OSB No. 003560

mike.porter@millemash.com

MILLER NASH GRAHAM & DUNN LLP

3400 U.S. Bancorp Tower

Ill S.W. Fifth Avenue

Portland, Oregon 97204

Telephone: (503) 224-5858

Facsimile: (503)224-0155

Attorneys for Defendants

University of Oregon and Dana Dean Altman

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

JANE DOE,

Plaintiff,

CVNo. 6:15-cv-00042-MC

DECLARATION OF TAMMY AUSTIN

V.

UNIVERSITY OF OREGON, DANA

DEAN ALTMAN, as an individual,

Defendants.

Page 1 - Declaration of Tammy Austin

70000153.1

MILLER NASH GRAHAM & DUNN LLPP

ATTORNEYS AT LAW

TELEPHONE: (503) 224-5858

34UU U. S. BANCORP TOWER

Ill S. W. FIFTH AVENUE

PORTLAND. OREGON 97204

Exhibit A 

Page 1 of 3

Case 6:15-cv-00042-MC Document 7-1 Filed 02/09/15 Page 1 of 3
I, Tammy Austin, declare that:

1. I am Brandon Austin's mother. I have personal knowledge of the facts set

forth in this declaration. I am competent to testify with respect to the matters set forth below.

2. I have never spoken with, nor given any statement to plaintiffs attorneys,

John Clune and Jennifer Middleton, nor any of their representatives.

3. During December 2013, Brandon decided to transfer from Providence

College in Rhode Island and other schools, including the University of Oregon, recruited

Brandon to play basketball. During the time when Brandon was being recruited by the

University of Oregon, I spoke with University of Oregon Assistant Coach Tony Stubblefield in

person and Coach Dana Altman over the phone.

5. Coach Altman asked me about the fact that my son had been subjected to

the discipline process at Providence and asked what the nature of the discipline was. I told

Coach Altman that my son had an altercation with another person.

6. I never told Coach Stubblefield, Coach Altman, or any other

representative of the University of Oregon anything to indicate that the disciplinary proceeding

against Brandon at Providence was for allegations of a sexual nature or related to alleged sexual

misconduct.

7. I did not tell anyone at the University of Oregon about the nature of the

allegations at Providence because my son denied any misconduct and because I believed the

allegations were false. I did not see the point of having false allegations follow Brandon to his

next college or university

Page 2 - Declaration of Tammy Austin

70000153.1

MILLER NASH GRAHAM & DUNN LLP

ATTORNEYS AT LAW

TELEPHONE; (i03) 224-5858

3400 U. S. BANCORP TOWER

Ill S. W. FIFTH AVENUE

PORTLAND, OREGON 97204

Exhibit A 

Page 2 of 3

Case 6:15-cv-00042-MC Document 7-1 Filed 02/09/15 Page 2 of 3
8. I have reviewed the complaint against Coach Altman and the University

filed by attorneys Jennifer Middleton and John Clune. Paragraph 24 states that I said "We told

them everything. They knew everything. " It implies that I told University coaches that the

allegations against Brandon were of a sexual nature. That is not tme and I never told Coach

Altanan or any representative of the University that the allegadons against Brandon were of a

sexual nature or involved an alleged sexual assault.

Pursuant to 28 USC § 1746, 1 declare under penalty ofpeq'ury that the foregoing

is true and correct.

EXECUTED this _ day of January, 2015, at _,

Tammy Austi

Page 3 - Declaration of Tammy Austin

70000153.1

MILLER NASH GRAHAM & DUNN LLP

ATTORNEYS AT LAW

TELEPHONE; (i0)» 214. 5858

i<0» U.5. BANCORP TOWER

Ill S. W. FIFTH AVENUE

PORTLAND. OREGON 972114

Exhibit A 

Page 3 of 3

Case 6:15-cv-00042-MC Document 7-1 Filed 02/09/15 Page 3 of 3