reasonable time, place and manner restrictions." Memo, ftn. 3. [10] Plaintiffs respectfully submit that the key word here is "reasonable," and, in the context of the instant matter, "reasonable" is a matter for factual determination.
divorce the actions of Officers O'Neill and Keness from plaintiffs' allegation that, [13]
need clarification until November, 1994 (or January 25, 1995, dependant on when the Court determines the permit restriction became "well established."
declares that an activity (specific display of 2 signs and 2 flags), which has continued everyday in plain sight of millions, is a crime.
regulation, and thus have their complaint resolved on the premise of "official immunity."
without first conducting a factual hearing. See, Third Motion for Sanctions (R-49), Exhibit 6, pg. 67, cf, Declaration of William Thomas, filed this date, 13 and 26.