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,

v.

DECLARATION OF JAMES WOOD

(In Support of Defendants' Motion for

BRYANT ENGE, CHARLIE HALES, Summary Judgment)

CITY OF PORTLAND,

DEFENDANTS.

I, James Wood, declare as follows:

1. I am employed by G4S Security International as an armed Mayor's Security

Detail Sergeant. I have held this position since March 2013.

2. My duties including providing security at the entrances and within Portland City

Hall and the Portland Building. I also provide security to the Mayor's office and City Council

sessions and other Mayor details as assigned.

3. In my experience and observation, individuals visiting City offices, especially

City Council sessions, can be very disruptive and engage in inappropriate behavior which can

Page 1 — DECLARATION OF JAMES WOOD

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 20 Filed 10/30/15 Page 1 of 6
result in exclusions and possibly arrest. The security of the buildings and its occupants, whether

citizens, elected officials or staff, 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. These activities are documented in written reports

and video recordings.

5. As part of my employment, I write incident reports documenting security

concerns and disruptive and/or inappropriate behaviors.

6. Mr. Joe Walsh is a frequent visitor to City Hall and its adjacent rights of way.

7. Mr. Walsh frequently protests outside City Hall using an amplified "bull horn" to

broadcast his opinions.

8. In my experience and observation, Mr. Walsh regularly attends City Council

meetings to observe and provide public testimony.

9. Mr. Walsh has a history of being disruptive and combative while attending City

Council meetings.

10. I was present at the March 12, 2014 City Council meeting and observed Mr.

Walsh's behavior. During that session, Mr. Walsh testified on several agenda items. He became

louder and more accusatory to the Mayor and Commissioners each time he testified. Mr. Walsh

was warned multiple times to not interrupt, but he continued to do so. Mr. Walsh testified on the

last agenda item regarding low income housing. When Mr. Walsh sat down at the presentation

table, he banged his cane on the table so it was audible to the back of the room. Mr. Walsh

yelled at the Council members, accusing them of misuse of funds, and shouted over

Commissioner Fish. After he testified, Mr. Walsh continued to yell from his seat in the spectator

section. The Mayor ordered Mr. Walsh out of the Council Chambers and I escorted him out.

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

report I wrote on March 12, 2014 documenting Mr. Walsh's behavior on that date.

Page 2 — DECLARATION OF JAMES WOOD

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 20 Filed 10/30/15 Page 2 of 6
12. I was present at the May 7, 2014 City Council meeting and observed Mr. Walsh's

behavior. Mr. Walsh testified regarding revised handicap parking restrictions in downtown

Portland. Just prior to Mr. Walsh's testimony, Lisa Frisch had testified providing testimony in

favor of the restrictions. When Mr. Walsh sat down at the table, he banged his cane on the table.

He immediately became accusatory with the Council and voiced his displeasure for new

restrictions. Mr. Walsh's voice was elevated, his face reddened and he appeared to be getting

angrier the more he spoke. Mr. Walsh became very argumentative with the Mayor and swore at

him. After Mr. Walsh left the Chambers, Ms. Frisch requested an escort from the building.

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

report I wrote on May 13, 2014 documenting Mr. Walsh's behavior on May 7, 2014.

14. I was present at the September 10, 2014 City Council meeting and observed Mr.

Walsh's behavior. Mr. Walsh had spoken in support of one agenda item and attempted to speak

on additional agenda items when Mayor Hales stopped him because those statements were

scheduled for the following week. Mr. Walsh became extremely upset, boisterous and

confrontational. In spite of being directed by both Mayor Hales and Commissioner Fish several

times to calm down or leave chambers, Mr. Walsh continued to be disruptive, yelling and

slamming his hand onto the conference table at least twice. Eventually, Mayor Hales called a

recess to the City Council meeting and directed security to escort Mr. Walsh from chambers. I,

with the assistance of other security officers, escorted Mr. Walsh out of chambers. I directed Mr.

Walsh to leave the building and informed him he was excluded for 24 hours.

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

report I wrote on September 10, 2014 documenting in detail Mr. Walsh's behavior on that date.

16. I was present at the May 13, 2015 City Council meeting and observed Mr.

Walsh's behavior. I was seated directly across from Mr. Walsh and Steven Entwhistle. Jessie

Sponberg was to my left. It appeared to me that these three gentleman were intentionally

Page 3 — DECLARATION OF JAMES WOOD

PORTLAND CITY ATTORNEYS OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 20 Filed 10/30/15 Page 3 of 6
antagonizing the Council by yelling statements about stopping the reservoir demolition and

actively encouraging audience participation in the yelling. During breaks in the City Council

meeting, I observed Walsh, Entwhistle and Sponberg collaborating on their efforts to disrupt the

meeting. Each time Council reconvened and the Council members attempted to conduct City

business, the noise from the audience became deafening with chants to stop the demolition of the

reservoirs and loud cascades of "Boo" and "No" all encouraged and directed by Walsh,

Entwhistle and Sponberg. At one point, Mr. Walsh walked over and laid down on the floor

where Constantin Severe was testifying. He rolled up newspapers into a makeshift megaphone

and in a loud and boisterous voice yelled "Boos" and "No," interrupting Mr. Severe's testimony.

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

report I wrote on May 20, 2015 documenting in detail Mr. Walsh's behavior on May 13, 2014.

18. I was present at the July 8, 2015 City Council meeting and observed Mr. Walsh's

behavior. Mr. Walsh requested Agenda Item #743 be pulled from the consent agenda. However,

just prior to regular Agenda Item #743, Mr. Walsh had exited the chamber. Since Mr. Walsh

was absent, Council moved to the next agenda item and began its verbal presentation. When Mr.

Walsh returned to chambers he appeared extremely agitated and started using a very loud and

boisterous voice directed at the Mayor and the Commissioners. Mr. Walsh wanted the council to

stop the current proceeding and return to Agenda Item #473. When the request was denied, Mr.

Walsh stormed up to the conference table, slammed his hand onto it, and in a very loud

boisterous voice began arguing his position. Mr. Walsh would not stop screaming and disrupting

the City Council session. Mayor Hales declared Mr. Walsh to be trespassing and excluded him

from City Hall for 60 days. The City Council meeting was recessed. I approached Mr. Walsh

and requested that he leave the building. Outside chambers, Mr. Walsh confronted Mayor's

Chief of Staff Josh Alpert before exiting the building.

Page 4 — DECLARATION OF JAMES WOOD

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 20 Filed 10/30/15 Page 4 of 6
19. Attached to this Declaration as Exhibit E is a true and correct copy of the incident

report I wrote on July 8, 2015 documenting in detail Mr. Walsh's behavior on that date.

20. A Formal Exclusion letter was given to Mr. Walsh on July 15, 2015.

21. On July 15, 2015, while I was on duty at City Hall's main entrance on SW 4th

Avenue, Mr. Walsh attempted to enter the building. I informed him that he was trespassing. Mr.

Walsh ignored me, walked away and entered the Pt floor men's restroom. I called the security

supervisor, John Chandler, and informed him of Mr. Walsh's presence in the building.

22. 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 , 2015.

Page 5 — DECLARATION OF JAMES WOOD

PORTLAND CITY ATTORNEY'S OFFICE

1221 SW 4TH AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 20 Filed 10/30/15 Page 5 of 6
CERTIFICATE OF SERVICE

I hereby certify that I served the foregoing DECLARATION OF JAMES WOOD on:

Joseph F. Walsh

7348 SE Division Street

Portland, OR 97206

Plaintiff-Pro Se

on October 30, 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

013-tifiN Pht#11\

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 ATTORNEYS OFFICE

1221 SW 4T" AVENUE, RM 430

PORTLAND, OREGON 97204

(503) 823-4047

Case 3:15-cv-01666-SI Document 20 Filed 10/30/15 Page 6 of 6