ADMIT: I can understand why folks might think I'm kind of
nuisance (E.C., Exhibit 6, pg. 6), but I don't mean to offend
anybody, but I know that my own purpose is, and it is not to
1
offend merely to discover Inconsistencies in logic, reason, and
judgment. Id.
That my vigil at the White House is an exercise in
civil disobedience; rather it is sincerely believed to be a
positive promotion of reason and logic, toward a more perfect
experience. Id.
AVER: I have tried to "keep my toes on the line,' of the
First Amendment, not because I think it's wrong, but because I
think it's my responsibility to communicate as effectively as my
limited resources allow.
AVER: "My problems" (as opposed to problems that others are
causing for me) in not avoiding an appearance of scofflawishness
has centered not so much on the definitions of a few certain
Words (e.g., 'camping," "casual sleep," "signs," 'structures'),
as much as the fact that the definitions constantly shift
according to the predilection for various individuals. Exhibits
6, pg. 7, see also pg. 44.
DENY: Being able to conceive of a possibility whereby any
reasonable person, who know anything about all this could
seriously believe that I have made less than heroic efforts to
continue doing what I have been doing since June 1981 without
offending the defendants, or their regulations. See, Thomas v.
United States, 696 F.2d 702, 713
AVER: I think my communicative efforts have been understood,
to Some degree, by many people. Exhibits 1-3.
ADMIT: I am motivated by religious beliefs which, I
sincerely think, will further the best interests of the human
2
race. Exhibit I-A
ADMIT: This very Court once wisely recognized, I'm only
doing what I'm doing because of my sincere (quite likely, in some
respects, mistaken, what can I say, nobody's perfect?) "religious
beliefs,' which, with respect to the exercise thereof as this
Court honorably 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 was in 'enforcing the
regulations' at issue." United States v. Thomas and Thomas,
Cr. No. 87-62, J. Richey, filed April 23, 1987, reversed, on
other grounds, 864 F.2d 188, supra.
ADMIT: Believing the Court understands all this. Exhibit 5.
ADMIT: Being somewhat disappointed that I can't honestly say
I believe, the Court is acting with individual responsibility.
Exhibit 6, pgs. 9-10.
ADMIT: Consequent to my last admission, I do not think the
Court's abdication of individual responsibility under peer
pressure in the best interests of truth, justice, freedom,
equality, of this country.
DENY: (adamantly): Any conscious animosity toward this Court,
counsel, defendants, or any other human being on the face of the
planet.
ADMIT: In my November lOth letter to Mr. Robbins, I wrote:
'(I)n the unlikely event that you too think this
"sign" is a "structure" under the applicable regulatory
provisions, please specify the precise structural alteratlons you
believe would be required to bring the "structure" into
compliance as a 'sign.' ADDITIONALLY, PLEASE MAKE THAT
INFORMATION AVAILABLE TO ME AS SOON AS POSSIBLE SO WE CAN
DISCUSS POSSIBLE CORRECTIVE MEASURES THEREBY AVOIDING A
BASELESS ARREST, AND THE UNNECESSARY DISRUPTION OF MY
RELIGIOUS ACTIVITY." Declaration of William Thomas in
Support of the Complaint, Exhibit 1, pg. 2.
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AVER: That the intent of my letter to Mr. Robbins was to
arrive at an understanding that would enable us to continue our
harmless religious activities while avoiding, arrest, threats,
intimidation, criminal, or civil,
litigation,
ADMIT: I believe that Mr. Meyers' letter of January 20,
1995 bears further witness to the fact that this honorable Court
mlght be taking this matter less seriously than tbe Founding
Fathers Sought to insure that it would be taken; otherwise I
just can't figure out how it could have come to a polnt where it
might even be appropriate for it to be in the Record.
ADMIT: Defendants might he "not guilty," however:
DENY: Being able to conceive of any possible combination of
circumstances under which Defendant Robbins, or Mr. Meyers could
be unaware of what we're saying, due to their long term, intimate
involvement. E.g., Exhibit 7.
DENY: Any personal knowledge or belief that anything
alleged in the complaint is factually incorrect.
ADMIT: We have made similar claims of police abuse under
color of regulation. Exhibit 6, pg. 42.
DENY: Any impression that the Process has ever tried to
resolve tbose clalns withln the intent of truthful and
constructive law.
AVER: Still, I find it extremely depressing to realize that
many exceptionally well-respected and highly intelligent human
beings do, who probably sincerely believe that they really do
understand me, don't seem to have a clue about my actual purpose.
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ADMIT: I believe that Marcelino Corneil wouldn't have been
killed if the Courts of this district had taken these serious
matters seriously years ago, and compelled Messrs. Robbins,
Meyers, et. al. to formulate and adhere to civilized, reasonable
regulatory enforcement policies.
ADMIT: A strong suspicion that, unless this Court acts
seriously on this matter (as opposed to approaching it in an
'It's those campers again, filing more of their conspiracy
theories, or whatever the Court's thinking), the United States
may continue to enjoy a materially comfortahle and convenient (at
least for a short time), but it will have proven itself morality
and spiritually bankrupt -- God forgive me if I'm mistaken.
ADMIT: I conceived, and wrote, Plaintiffs' Motion for
Reconsideration of Denial of the TRO Application, or,
Alternatively to Dismiss for Frivolity.
DENY: That I'm bored, idle, petty, hateful or even stupid
enough to intentionally launch a personal attack on this Court
or, God belp me, anyone else, particuiarly after having spent as
much time and energy (however crudely and ineptly) trying to
convince the Court to take me seriously.
ADMIT: My wife and other people have suggested that the tone
of my voice and my selection of words, coupled with my eccentric
sense of humor, may tend to offend. I think they may have a
point, I've been making a serious effort to behave less
offensively.
ADMIT: To me the despicability of the ad hominem argument is
that it transforms reason into Insanity by ignoring the basic
5
questions at issue
DENY: To the very best of my recollection, that I have EVER
intentionally written ANYTHING for the purpose of personally
attacking ANY person.
ADMIT: Owing to my compulsion to ferret out hypocrasy,
counsel's charge of "ad honinem attack" forced me to look inward
and reconsider, once again, whether I have fallen so out of touch
with realIty that I had dropped to the level of attacking the
person, rather than what I (mistakenly or not, so long as the
mistake is honest) consider to be the intellectual absurdity of
the person's position.
ADMIT: During the course of my Inward Investigation, one
person told me that, In places, my writing could easily be
considered "arrogant." As an example, that person specifically
Identified the words, "plaintiffs offer the Court two options."
The perceived arrogance was that I presumed the power of limiting
the Court to only two options.
DENY: Ever being so arrogant (I'd call it "stupid") as to
think I might limit the Court's options.
ADMIT: Another person said that providing space where 'the
Court may insert its rationalizations' sounded sarcastic.
DENY: That I could think of anything else to write in spaces
where it appeared some rational explanation was called for, but
I, honestly couldn't come up with one.
ADMIT: All I can say is, in both the Proposed Order for a
Temporary Restraining Order, and the Proposed Order to Dismiss
for Frivolity, I tried to be scrupulous in relating reality as I
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honestly believe it to be. In this light, I simply could not
think of a way to frame the latter Proposed Order in a light more
favorahle to the Court.
FERVENTLY HOPE: We can now all firmly put personal
perspectives behind us, and proceed to the issues at bar.
In sincere service to Truth, as best I can perceive it, and
Peace through Reason and justice,
William Thomas
January 27, 1995