The district court's disposition of this case champions the premise that
individuals can apply for and be granted a permit, allowing a specific act; be
threatened and intimidated by the police for doing that specific act; file a lawsuit to
redress those enforcement excesses; be advised by defense counsel during litigation that
the exercise of the permitted action was, indeed, a regulatory violation, and have the
1
complaint dismissed under the doctrine of "official immunity." This administrative
approach to reality makes a laughingstock of the permit process, and promotes the
abuse of police power under the pretext of agency policy..
As more fully explained in the Memorandum, given the facts in the instant matter, to remain consistent with this Court's decision in Crawford-El, this case must also be remanded
for further consideration.
For the Court's cross-referencing convenience a hypertext version of this Motion, linked to the entire record of this case, is available at http://prop1.org/clues/94appeal/mgfp1016.htm
Respectfully submitted the 23rd day of October, 1996
___________________________________
William Thomas, Appellant, Pro Se
P.O. Box 27217
Washington, D.C. 20038
(202) 462-0757
____________________________________
Concepcion Picciotto, Appellant, Pro Se
Post Office Box 4931
Washington, D.C. 20008
____________________________________
Ellen Thomas, Appellant, Pro Se
P.O. Box 27217
Washington, D.C. 20038
(202) 462-0757
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing Motion to Govern Further Proceedings and the accompanying Memorandum in Support has been mailed, postage prepaid, this 23rd day of October, 1996, to:
Kimberly N. Tarver
Assistant United States Attorney
Judiciary Center Building
555 4th Street N.W., Rm 10-106
Washington, D.C. 20001
William Thomas, Appellant, pro se
P.O. Box 27217
Washington, D.C. 20038
202-462-0757
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