DAVID LANDRUM, Oregon State Bar ID Number 955425

Senior Deputy City Attorney

Email: david.landrum@portlandoregon.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 KARLA

v. MOORE-LOVE

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

CITY OF PORTLAND, Summary Judgment)

DEFENDANTS.

I, Karla Moore-Love, declare as follows:

1. I am employed by the City of Portland as the Clerk to City Council. I have held

this position since March 29, 2001.

2. Some of my responsibilities include overseeing the City Council meetings to

maintain a journal of its proceedings, maintain a record of the Council's actions, and ensure that

City Council documents are in compliance with applicable laws.

3. Either I or the Assistant Clerk are present in the City Council Chambers during

City Council meetings.

4. I am familiar with Joseph Walsh.

Page 1 — DECLARATION OF KARLA MOORE-LOVE

PORTLAND CITY ATTORNEYS OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 18 Filed 10/30/15 Page 1 of 4
5. In my experience and observation, Mr. Walsh frequently appears at City Council

meetings to observe and to provide testimony.

6. In my experience and observation, Mr. Walsh has a history of being combative

and disruptive during City Council meetings.

7. City Council meetings are conducted and recorded in accordance with ORS

192.630 and 192.650 and Portland City Code Chapter 3.02.

8. All City Council meetings are video-recorded and live-streamed on the interne

and broadcast on public access channel 30 by a vendor, Portland Community Media (PCM). The

video-recordings going back to 2003 are maintained for archival purposes forever. The most

recent meetings are available on the City's webpage. The City has a process to move older videos

to a YouTube channel, https://www.N otittibe.comlchannel/I Wel11_1117C - \VIA tBXisMPH WG65g 

play lists. 

9. Once the Council session is complete, YouTube automatically makes the video

available for on demand viewing. The Bureau of Technology Services becomes the custodian of

these recordings.

10. The audio portion of City Council meetings are available on the City Auditor's

webpage through efiles. The City Auditor's Office is the custodian of these recordings.

11. The City Council meetings are also broadcast with live closed captioned text. The

closed captions are provided through a vendor, LNS Captioning. I and other members of the

Clerk's office review the closed caption and insert the correct names to the text. To create the

official minutes the Clerk's office combines the Council Agenda Disposition with the reviewed

closed caption file provided by LNS Captioning.

12. Beginning in early 2014, Mayor Hales began giving a brief admonishment at the

beginning of the public testimony portion of City Council meetings reminding individuals

observing and testifying that they were expected to observe basic decorum while in council

Page 2 — DECLARATION OF KARLA MOORE-LOVE

PORTLAND CITY ATTORNEYS OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 18 Filed 10/30/15 Page 2 of 4
chambers. The basic decorum allows them to give a thumbs up or wave of the hand in support,

but prohibits vocal demonstration that might interrupt or drown out testimony.

13. Attached to this Declaration as Exhibit A is a true and correct copy of excerpts

from the City Council minutes for January 8-9, 2014.

14. Attached to this Declaration as Exhibit B is a true and correct copy of excerpts

from the City Council meeting minutes for March 12, 2014.

15. Attached to this Declaration as Exhibit C is a true and correct copy of excerpts

from the City Council meeting minutes for May 7, 2014.

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

from the City Council meeting minutes for September 10, 2014.

17. Attached to this Declaration as Exhibit E is a true and correct copy of excerpts

from the City Council meeting minutes for May 13, 2015.

18. Attached to this Declaration as Exhibit F is a true and correct copy of excerpts

from the City Council meeting minutes for July 8, 2015.

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 21,2015.

Karla oore-Love

Page 3 — DECLARATION OF KARLA MOORE-LOVE

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 18 Filed 10/30/15 Page 3 of 4
CERTIFICATE OF SERVICE

I hereby certify that I served the foregoing DECLARATION OF KARLA MOORE-LOVE on:

Joseph F. Walsh

7348 SE Division Street

Portland, OR 97206

PlaintiffPro Se

on October 3O , 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):

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

Service in Portland, Oregon.

❑ by hand delivery.

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

❑ by facsimile transmission.

❑ by email.

Page 1 — CERTIFICATE OF SERVICE

DAVID LANDRUM, OSB #955425

Senior Deputy City Attorney

DANIEL SIMON, OSB #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 18 Filed 10/30/15 Page 4 of 4