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,

v.

DECLARATION OF TRACEY LE

(In Support of Defendants' Motion for

BRYANT ENGE, CHARLIE HALES, Summary Judgment)

CITY OF PORTLAND,

DEFENDANTS.

I, Tracey Le, declare as follows:

1. I am employed by the City of Portland, Bureau of Technology, as a business

system analyst. I have held this position since 2008.

2. Some of my responsibilities include support of Bureaus'/Offices Content

Manager to maintain their website, and make sure the City Council videos are available on the

website.

3. I am part of a three person team responsible for maintaining and uploading City

Council meeting videos on City Council YouTube channel and on the City's website.

Page 1 — DECLARATION OF TRACEY LE

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 22 Filed 10/30/15 Page 1 of 4
4. All City Council meetings are video-recorded and live-streamed on the internet

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

5. Once the Council session is complete, PCM provides the video to the City of

Portland Bureau of Technology who becomes the custodian of these recordings.

6. The video footage is maintained for archival purposes for eternity.

7. Video from City Council meetings from June 23, 2015 to the present are available

on the City's webpage, http://www.portlandoregon.gov/video/player/?tab=council. They are also

available on YouTube.

8. Beginning in June 2015, the City began to move all its City Council videos

from the City webpage to a YouTube channel, https://www.youtube.com/channel/

UCcPIUh7CWwtBXisMPHWG65g/playlists.

9. Older videos are being migrated to YouTube as we receive requests for them.

10. City Council meeting videos are public records and can be obtained by making a

public records request to the City.

11. Attached to this Declaration as Exhibit A is a DVD containing a true and correct

copy of excerpts from videotapes of City Council meetings held in 2014-2015.

12. The video on Exhibit A labeled as "cc010914" is a true and correct copy of video

from the City Council afternoon meeting on January 9, 2014.

13. The video on Exhibit A labeled as "cc031214" is a true and correct copy of video

excerpts from the City Council morning meeting on March 12, 2014.

14. The video on Exhibit A labeled as "cc050714" is a true and correct copy of video

excerpts from the City Council morning meeting on May 7, 2014.

15. The video on Exhibit A labeled as "cc091014" is a true and correct copy of video

excerpts from the City Council morning meeting on September 10, 2014.

Page 2 — DECLARATION OF TRACEY LE

PORTLAND CITY ATTORNEYS OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 22 Filed 10/30/15 Page 2 of 4
16. The video on Exhibit A labeled as "cc051315" is a true and correct copy of video

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

17. The video on Exhibit A labeled as "cc070815" is a true and correct copy of video

excerpts from the City Council morning meeting on July 8, 2015.

18. 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 024- , 2015.

Page 3 — DECLARATION OF TRACEY LE

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 22 Filed 10/30/15 Page 3 of 4
CERTIFICATE OF SERVICE

I hereby certify that I served the foregoing DECLARATION OF TRACEY LE on:

Joseph F. Walsh

7348 SE Division Street

Portland, OR 97206

Plaintiff-Pro Se

on October 3v , 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

pa,v„ VoNlYi

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 22 Filed 10/30/15 Page 4 of 4