State's Initial Disclosures

The State Defendants (Rep. Shelly Boshart Davis and Renee Perry) hereby submit their initial disclosures pursuant to Fed. R. Civ. P. 26(a). By disclosing this information, the State Defendants are not waiving any privileges and protections, including attorney-client privilege, work-product privilege, and anticipation of litigation protection. The State Defendants further retain the right to make any objections concerning the disclosure and use of this information.The State Defendants reserve the right to update or correct this document in the future as information becomes better known or understood through discovery and further evaluation.

I. Witnesses

The name and, if known, the address and telephone number of each individual likely to have discoverable information – along with the subjects of that information –that the State Defendants may use to support their claims or defenses, unless the use would be solely for impeachment.

Response: Without repeating the below for each listed individual, all State Defendants and employees can be reached through the State Defendants’ counsel.

1. Rep. Shelly Boshart Davis: Representative whose staff was involved in disagreement with Plaintiff on January27, 2025, and who requested that the Plaintiff not return to her offices without police escort.
2. Renee Perry: Chief of Staff for Rep. Shelly Boshart Davis. Witness to the disagreement withPlaintiff on January 27, 2025.
3. Brett Hanes: Legislative Administrator for Oregon State Legislature. Advised Plaintiff that he may not enter Capitol Building without notice to security and escort and later lifted the requirement.
4. Trooper Bryan Kolacz: Oregon State Police officer and reporting officer to the incident on January 27, 2025.Escorted Plaintiff from the Capitol.
5. Nikkola Prevett: Oregon State Police dispatcher who received alarm calls from Rep. Boshart Davis’s office on January 27, 2025.
6. Dru Draper: Legislative Assistant in Rep. Boshart Davis’s office who witnessed the disagreement between staff and Plaintiff on January 27, 2025.
7. Brad Brainard: Security Manager for Oregon Legislative Administration. Received alarm calls from Rep. Boshart Davis’s office on January 27, 2025, and involved in security decision-making regarding restrictions to Plaintiff’s access to the Capitol following the incident.
8. Lt. Casi Hegney: Oregon State Police, Capitol Mall. Involved in security decision-making regarding restrictions to Plaintiff’s access to the Capitol following the incident January 27,2025.
9. Captain Christopher Zohner: Oregon State Police, Capitol Mall. Involved in security decision-making regarding restrictions to Plaintiff’s access to the Capitol following the incident January 27,2025.
10. Logan Isaac: Plaintiff. Participant in January 27, 2025 incident and subject of Capitol restrictions, which were later lifted.

II. Documents, items, and information

A copy – or a description by category and location– of all documents, electronically stored information, and tangible things that the StateDefendants have in their possession, custody, or control and may use to support their claims and defenses, unless the use would be solely for impeachment.

Response: The State Defendants have in their possession, custody, or control incident reports, relevant policies and procedures, internal communications, external communications, and recordings. Some of these materials may only be produced under a stipulated protective order, or other order of the court. Some of these materials may also be protected by attorney-client privilege, work-product privilege, and anticipation of litigation protection and therefore not subject to disclosure.

III. Damages

A computation of each category of damages claimed by the disclosing party –who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered.

Response: Not applicable to the State Defendants.

IV. Insurance

For inspection and copying as under Rule 34, any insurance agreement underwhich an insurance business may be liable to satisfy all or part of a possible judgment in theaction or to indemnify or reimburse for payments made to satisfy the judgment.

Response: The State Defendants are self-insured under the rules and limitations of the Oregon Tort Claims Act, ORS 30.265 et seq.

DATED June 9, 2026.