Exhibit 16

DECLARATION OF WILLIAM THOMAS IN SUPPORT OF OF VIDEO TAPE EXHIBIT

In hope of developing evidence to the end that truth may be ascertained and proceedings may be justly determined, plaintiff submits a video tape in support of his opposition to the respective motions to dismiss or for summary judgment of the federal defendants and Captain Radzilowski. Pl's Exhibit V.T.@., see also, Motion for Judicial Notice, filed this date.

To facilitate understanding, the tape has been divided into Segments 1-11, Segment I begins at 0 minutes, 10 seconds, and Segment 11 ends at 13 minutes, 54 seconds (0m 10s - 13m 54s).

The first five segments of the Video Tape Exhibit are TV news and commentaries about the closure of Pennsylvania Avenue, intended to represent publicly perceptions, and actual effects of the physical barriers at issue. this segment also highlights defendants' perception that their "official duties" mandate, when they deem necessary, that they transcend "local and federal law." V.T., 1m-22s -2m 30s.

Segment 6 tries to show the location and placement of the concrete barriers which block Pennsylvania Avenue, Jackson and Madison Place, line H Street, and surround Lafayette Park.

Segments 7-9 show plaintiff's demonstration and arrest on May 26, 1995.

Segments 10-11 show two other recent demonstrations on Pennsylvania Avenue.

The segments depicting the May 26th arrest, which appear on the accompanying video, were edited from a source tape. The source tape, parts of which was recorded by two different camera persons, contains a few bits and peices which were edited for convenience sake. Should the Court or counsel desire an edited version of the source that, or should iforthcoming comments by counsel of the Court implicate the relevence of additional information, which may be contained on the tape, the source copy is available.

Plaintiff prays, the Court to look past the shaky camera work, glitches edits, and poor visual quality of the 14-minute tape. Being a result of his own personal choices, plaintiff does not complain of the long hours, low tech and lack of funds which limit the quality of his work product, so an apology isn't exactly appropriate. So, plaintiff humbly urges the Court not to allow the tape's unprepossessing form, blind the Court from viewing the material in "a light most favorable" to the non-movant. Reuber v. United States, 750 F.2d 1039, 1061-63 (D. C. Cir. 1984), Cf., John, 7:24. Pursuant to the provisions of Local Rule 106(h), I declare, under penalty of perjury that the foregoing is true and correct to the best of my knowledge and recollection. Executed on this 19th day of July, 1995.

______________________
William Thomas
2817 11th Street N.W.
Washington, D.C. 20005
202-462-0757