Memorandum - Factual Background

FACTUAL BACKGROUND

Since June, 1981, plaintiffs, perennial truth seekers, have "engaged in twenty-four-hour-a-day vigil(s) on the sidewalk bordering Lafayette Park, across the street from the White House (to seek wisdom and honesty, and) "to warn the public about the dangers of nuclear war." United States v. Picciotto, 875 F.2d 343, 347 (1989) parentheses inserted from, Declaration of William Thomas in Support of Sanctions ("Tom Dec"), Exhibit 1-A, filed this date. Compare Opp. TRO, pg. 2, no argument, 7 lines.

Mainly plaintiffs' vigils have had "a symbolic purpose." United States v. Thomas & Thomas, 864 F.2d 188, 193. However, under the impression that the public doesn't take the issues of wisdom, honesty and national preparations for indiscriminate mass murder as seriously as it ought, plaintiffs have chosen to sacrifice their own personal pleasures and comforts, "attempting to maintain a constant, all-weather, around-the-clock expressive

2

presence in Lafayette Park, without living accommodations, in what they see as "a humble service to the Creator of the Universe." "(P)ractically," they describe their effort as "be(ing) available (to the public) at all times for clarification of actual reality." Id. The public was likely to understand these efforts. Tom Dec., Exhibits 1-3.

Throughout, petitioners have done little more than think, express thought, and, occasionally, fall asleep. Public though they've been, there is no record to indicate they have caused even one real problem.[5] In the beginning plaintiffs' arguably eccentric but socially beneficial, materially harmless vigils enjoyed a significant degree of protection from official abuse under the guarantees of the Constitution. E.g.

"In the unusual circumstances (of an individual demonstrator's round-the-clock)
vigil" sleeping must be taken to be sufficiently expressive in nature to implicate First
Amendment scrutiny in the first instance." E.g., United States v. Abney,
534 F.2d 984, 985 (D.C.Cir 1976).


[5 As this very Court noted, "The Government stated that it had 'no interest in prohibiting any of these defendants from sleeping in the Park' and that its only interest in this case was in 'enforcing the regulations'." United States v. Thomas, et. al., USDC, Cr. No. 87- 60-64 (April 23, 1987), Order, pg. 2.]