Jurisdiction, Parties


Jurisdiction, Parties

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

     Concepcion Picciotto,        |
     Ellen Thomas,                |         C.A. No. ________________
     William Thomas,              |         Judge ___________________
           Plaintiffs pro se,     |
                                  |  APPLICATION FOR AN EXPEDITED  
          v.                      |  TEMPORARY RESTRAINING ORDER,
                                  |  
                                  |         CLASS ACTION, 
     The United States of America |       IN FORMA PAUPERIS     
     the U.S. Park Service        |            AND
     the U.S. Park Police, et. al.|PETITION FOR PRELIMINARY INJUNCTION 
           Defendants.            |

COMPLAINT

JURISDICTION

This Court has jurisdiction in this matter pursuant to Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1970), and 42 USC Sections 1985(3), and 1986, 18 USC Section 1961, 1964, 1965, 1966, and the First, Fifth, Ninth, and Fourteenth Amendments to the Constitution of the United States of America (hereinafter "the Constitution").

PARTIES

PLAINTIFFS

All named plaintiffs are adult human beings residing within the legal jurisdiction of the United States of America who regularly demonstrate at Lafayette Park for the global elimination of nuclear weapons.

William and Ellen Thomas maintain the Peace Park Vigil.

Concepcion Picciotto and William Thomas maintain the White House Vigil.

Et. al. includes other unnamed individuals who regularly and harmlessly demonstrate at Lafayette Park for any reason.

1

DEFENDANTS

Ostensibly, the United States of America exists to administer law to protect the rights and privileges of individuals within its legal jurisdiction.

The U.S. Park Service, pursuant to the provisions of the APA, but subject to the provision of the Constitution has legal jurisdiction over Federal Parks.

Richard Robbins is an Assistant Solicitor with the Department of Fish and Wildlife, U.S. Interior Department. Part of his official duties is to advise the Park Police on the enforcement of regulations in 36 C.F.R. 7 et. seq.

The U.S. Park Police is the law enforcement agency of the Department of Interior and the National Park Service.

Officer O'Neill is employed by the United States Park Police. Officer Keness is employed by the United States Park Police.

Officer X, who the Park Police refuse to identify, shot Marcelino Corniel on the White House sidewalk, December 20, 1994.