Proposed Order


William Thomas, et. al.       |   
      Plaintiffs pro se,      | 
       v.                     |          C.A. No. 95-1018
                              |       Judge Charles R. Richey
The United States, et. al.    |      
      Defendants.             | 


Defendants have closed Pennsylvania Avenue, and placed barriers around Lafayette Park with absolute disregard for all applicable regulations governing closure of public parks, . Defendants also plan to make other changes to the topography of the park and/or further restrict public access to the park.

UPON CONSIDERATION of plaintiff's Motion for a Preliminary Injunction pending resolution of the issues raised in the Complaint, this ___ day of _____, 1995, it be and hereby is

ORDERED defendants and officials of the D.C. Metropolitan Police Department be, and hereby are PRELIMINILY RESTRAINED from interfering with the exercise of plaintiff's First Amendment activity, and it is further,

ORDERED defendants are hereby preliminarily restrained from arresting plaintiff for engaging in lawful First Amendment activities under color of D.C.M.R. "Failure to Obey a Police Officer," and or D.C.M.R 24.101, and it is further

ORDERED that defendants are preliminarily enjoined from (1) making any further changes to Lafayette Park, and it is

FURTHER ORDERED that defendants are preliminarily enjoined from (2) from replacing the temporary concrete barriers presently enclosing Lafayette Park with any more permanent barriers, and from constructing any fence, wall or other obstruction to open access around Lafayette Park, and it is

FURTHER ORDERED, that defendants are preliminarily enjoined from closing the Park, except as provided by law, pending the resolution of this complaint.

_____________________________________ U.S. District Court Judge