Peter Michael Meloy MELOY LAW FIRM P.O. Box 1241 Helena MT 59624-1241 (406) 442-8670 [email protected] Attorney for Petitioner

MONTANA FIRST JUDICIAL DISTRICT COURT, LEWIS AND CLARK COUNTY ______THE , ) BIGFORK EAGLE, THE BILLINGS ) GAZETTE, BOZEMAN DAILY ) CHRONICLE, THE ) STANDARD, GREAT FALLS ) TRIBUNE, HAVRE DAILY NEWS, ) HELENA INDEPENDENT RECORD, ) THE DAILY INTERLAKE, KECI-TV ) KFBB-TV, KXLF-TV, KTVQ-TV, ) KULR-TV, LIVINGSTON ENTERPRISE, ) MILES CITY STAR, MISSOULIAN, ) AFFIDAVIT OF MONTANA NEWSPAPER ASSOCIATION ) JOHN S. ADAMS NEWS MONTANA, INC (as publishers of ) BIG HORN COUNTY NEWS, CARBON ) COUNTYNEWS AND STILLWATER ) COUNTY NEWS,) RAVALLI REPUBLIC, ) and THE SOCIETY OF PROFESSIONAL ) JOURNALISTS, MONTANA CHAPTER ) ) Plaintiffs, ) ) vs. ) ) THE MONTANA SENATE REPUBLICAN ) CAUCUS, THE MONTANA SENATE ) DEMOCRATIC CAUCUS, THE MONTANA ) HOUSE OF REPRENTATIVES ) REPUBLICAN CAUCUS and THE MONTANA ) HOUSE OF REPRESENTATIVES ) DEMOCRATIC CAUCUS. ) ) Defendants ) County of Lewis and Clark ) ) ss State of Montana )

I, John S. Adams, having been first duly sworn deposes and says:

1. I am the bureau chief for the Capital Bureau of the Great Falls Tribune a

daily newspaper of general circulation in Cascade County and throughout

the State of Montana;

2. Among my primary duties is to report on the activities of the Montana

Legislature; On Thursday, November 13th, 2014, I received a tip that the

House Republican Caucus was holding a publically unannounced

meeting in the basement of a Jorgenson’s restaurant. The person who

gave me the tip described the notice given to members as having been

made in writing and given out by members of the Republican leadership

to each of the members as “Republican caucus meeting, 8 p.m.

Jorgenson’s Banquet Room.”

3. I attended the meeting which was in progress when I arrived at

approximately 8:05 p.m. with Shane Castle, editor and publisher of the

Helena Vigilante newspaper. As soon as I entered the banquet room, the

Chair of the meeting, House Majority Leader Keith Reiger, interrupted

Representative Ryan Osmundson, who was talking about House Bill 2.

Reiger also handed out document entitled “11-13-14 Republican Caucus” to members who were present. Shortly after Castle and I arrived, the

meeting adjourned. I estimate there were at least 50 of the House

Republicans in attendance at the meeting called for the purpose of

discussing matter related to the upcoming session, including major pieces

of legislation that would be debated in the upcoming legislative session.

4. No public notice of the meeting was ever given and it appeared to me

that the members were surprised at my appearance and that they did not

expect any member of the public to attend the meeting.

5. This is the second publically unannounced House Republican caucus

meeting I have witnessed in the past two sessions. On April 16, 2013, I

witnessed and documented a closed-door House Republican caucus

meeting in the basement of the Capitol. No public notice of the meeting

was provided. I discovered this caucus after realizing that no Republican

members of the House could be located on the House floor or in

leadership offices. At least 50 members of the House Republican caucus

were gathered in a room in the basement known as the “bullpen.” When I

entered, a House Republican staffer tried to turn me away from the

meeting. I insisted the meeting was public, and refused to leave. The

House Speaker, former Rep. Mark Blasdel, was presiding over the

meeting. Bowen Greenwood, then the executive director of the Montana Republican Party, was also present at the meeting and whispered to

Blasedel upon my entering the room. The meeting adjourned shortly after

my arrival.

6. No public notice of the April 16, 2013 caucus meeting was ever given

and it appeared to me that the members were surprised at my appearance

and that they did not expect any member of the public to attend the

meeting.

AFFIANT SAYS NOTHING FURTHER

Dated this 18th day of November, 2014.

______John S. Adams

Signed and sworn to before me this 18th day of November, 2014

______Notary Public