IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SOUTHERN DIVISION

TRACIE PARK,

Plaintiff,

v. Civil No.96-3288-CV-S-3

THE FOREST SERVICE OF THE
UNITED STATES OF AMERICA, ET al,

Defendants.

DEFENDANT FOREST SERVICE'S INITIAL
DISCLOSURES, PURSUANT TO RULE 26,
FEDERAL RULES OF CIVIL PROCEDURE

Defendant Forest Service of the United States Department of Agriculture ("Forest Service"), by counsel, makes the following disclosures, pursuant to Rule 26(a)(1), Federal Rules of Civil Procedure.

A. Individuals likely to have discoverable information.

Lyn Carpenter
Incident Commander
1996 National Rainbow Family Gathering
Eleven Point District, Mark Twain National Forest
573/325-4233

James Scott
Law Enforcement Operations Chief
1996 National Rainbow Family Gathering
Sam Houston National Forest
National Forests in Texas
409/344-6205

Randy Moore
Forest Supervisor
Mark Twain National Forest
314/364-4621

Billy S. Ball
Supervisory Special Agent
National Forests in Texas
409/639-8501

Richard Glodowski
Assistant Regional Special Agent in Charge, R-9
Regional office, R-9
414/297-3198

Kim Thorsen
Special Agent, Operations and Policy Section
Washington Office
703/235-5918

Dennis Deason
Law Enforcement Officer
U.S. Forest Service
Salem District, Mark Twain National Forest
573/729-6656

Bruce Maldonado
Special Agent
Mark Twain National Forest
573/341-7463

Barb Severson
Law Enforcement Officer
Hoosier National Forest
812/547-9234

Robert Jacobs
Regional Forester (Region 9)
310 West Wisconsin Ave.
Milwaukee, WI 53203

Manuel R. Martinet
Director, Law enforcement Investigation
U.S. Department of Agriculture, Forest Service
Washington, D.C.

Jack Ward Thomas
Chief of Forest Service
U.S. Department of Agriculture, Forest Service
Washington, D.C.

B. Documents relevant to disputed facts.

Exhibit 1 May 20, 1996, DG message from Charlotte Wiggins, Public Affairs Officer, MTNF.

Exhibit 2 June 18, 1996, media release by
Charlotte Wiggins, Public Affairs
Officer, MTNF.

Exhibit 3 May 13, 1996, memorandum to Regional
Special Agents from Manual R. Martinet,
Director of Law Enforcement and
Investigation, W.O.

Exhibit 4 Law Enforcement Action Plan, 1996
Rainbow Family Gathering, Mark Twain National Forest.

Exhibit 5 June 19, 1996, Forest Supervisor's
Order, executed by Randy Moore, Forest Supervisor, MTNF.

Exhibit 6 March 9, 1989, Forest Supervisor's
Order, executed by Randy Moore, Forest Supervisor, MTNF.

Exhibit 7 June 19, 1996, Forest Supervisor's
Order, executed by Randy Moore, Forest Supervisor, MTNF.

Exhibit 8 June 24, 1996, Missouri Highway Patrol
Memorandum submitted by B.E. Chadwick,Captain,
Commanding Troop G.

Exhibit 9 December 1985, Forest Service Hand Book
policy reference road blocks on Forest Service lands.

Exhibit 10 June 20, 1996, Cooperative Agreement
between Forest Service, Department of Agriculture and
Missouri State Highway Patrol.

Exhibit 11 June 24, 1996, Operating Financial Plan
of the Cooperative Agreement between the Forest Service,
Department of Agriculture and the County of Oregon, Missouri.

Exhibit 12 September 11, 1996, statement submitted
by Dennis Deason, Law Enforcement Officer.

Exhibit 13 September 12, 1996, memorandum submitted
by Bruce Maldonado, Special Agent, to Billy Ball, Supervisory Special Agent.

Exhibit 14 June 28, 1996, Forest Supervisor's
Order, executed by Randy Moore, Forest Supervisor, MTNF.

Exhibit 15 February 28, 1995, Forest Service Manual
policy reference the carrying of firearms by law enforcement officers.

Exhibit 16 July 3, 1996, memo to the files,
submitted by Lyn Carpenter, Incident Commander.

Exhibit 17 July 3, 1996, Memorandum of Conversation
between Ellen Hornstein, Attorney, Office of General Counsel,
U.S. Department of Agriculture, W.O., and Kim Thorsen, Special Agent,
Operations and Policy Section, W.O.

Exhibit 18 Chronology of events during the 1996
Rainbow Gathering, MTNF.

Exhibit 19 July 15, 1996, 5300 memorandum from
Billy S. Ball, Supervisory Special Agent, R-8, submitted to
Rich Glodowski, Assistant Regional Special Agent in Charge, R-9.

Exhibit 20 August 12, 1996, personal letter from
John F. "Pancho" Smith to Jon Marsh, Regional Special Agent in Charge, R-9.

Exhibit 21 Forest Service law enforcement statistical report of enforcement actions taken during the 1996 Rainbow Gathering on the MTNF.

Exhibit 22 Missouri State Highway Patrol statistical report of enforcement actions taken during the 1996 Rainbow Gathering on the MTNF.

Exhibit 23 September 13, 1996, statement submitted by Barb Severson,
Law Enforcement Officer.

Exhibit 24 Incident Review Itinerary

In addition, Defendant Forest Service is in possession of a four-page 'Review Plan" which is being withheld as a privileged document,

Respectfully submitted,
Stephen L. Hill, Jr.
United States Attorney
Thomas M. Larson
Missouri Bar No. 21957
First Assistant U.S. Attorney

1201 Walnut Suite 2300
Kansas City, Missouri 64106-2149
Telephone: (816) 426-3130


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