Exhibit 17


I, William Thomas, hereby declare under penalty of perjury that the following is true and correct to the best of my knowledge and understanding:

DENY: Thinking I'm perfect, or that I know the truth.

ADMIT: Searching for Truth. Exhibit I-A

ADMIT: A strong aversion to hypocrisy.

DON'T DENY: I might be guilty of certain hypocrisies myself. Exhibit 6, pg. 7.

ADMIT: In an effort to ferret out my own personal inconsistencies, since June, 1981 I have engaged in what might be called "a symbolic purpose." United States v. Thomas 864 F.2d 188, 193.

DENY: Mistaking my perception of reality for Reality; however,

ADMIT: Although I don,t know much, I sincerely believe that I have a pretty good idea of the purposes inside my own head.

ADMIT: I'm funny looking, short, eccentric and not extraordinarily bright.

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


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


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.


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.


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


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


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