Proposed Order

            Plaintiff,                         Civil Action No. 84-3552




1. That defendants shall not interfere with plaintiff's inalienable right to,

a. seek wisdom, and attain moral perfection (Complaint attachment 3).

b. determine their own national identity, or lack thereof (Complaint attachment 3).

c. believe as their fundamental religious tenet that it is better to suffer harm than to inflict harm on others (Complaint attachment 9).

d. strive to embody this fundamental religious tenet in their lives.

e. consider the Earth to be the property of their Creator (Complaint attachment 19, 22).

f. refuse their services to any government, corporation, organization, policy, theology, ideology, or genocidal scheme which threatens the property of plaintiffs Creator (Complaint attachment 3).

g. live as penniless peace activists (Complaint attachment 3)

h. exercise the option of devoting their lives to the service of Truth, Justice, and Freedom (Complaint attachment 3)

i. harmlessly remain in a public park as long as they please.

j. promote a peaceful policy despite any warlike policy which the Government may, to the peril of its employees' eternal souls, choose to propagate.

k. enjoy individual freedom and personal excellence.

2. ORDERED, that Defendants shall adhere to the following definitions:
a. "Camping" does not mean '"causal sleep." (Federal Register. June 4, 1982, Vol. 47, No.. 108, P, 26301)

b. "Casual sleep" means sleep which occurs without resulting in demonstrable damage to park lands, and shall not constitute probable: cause: under 36 CFR 50.27. (Ibid.)

c. "Impacts which the area cannot sustain" means impacts which demonstrably exceed those of similar activities engaged in by the Government (i.e. the Inauguration activities, the Christmas Peace Pageant, e.g.·), (Ibid.)

d. "Property" does not include signs, literature, sound amplification, or video equipment, or tools required for the maintenance or protection of the foregoing, nor does it include protective plastic and rainwear, and other items necessary to protect plaintiffs from the elements during their demonstration.

3. ORDERED, that Defendants will not arrest or threaten to arrest plaintiffs for painting signs, or confiscate their paint, brushes, or signs under color of 'unlawful injury" (36 CPR 50.10(a)).unless such activity has demonstrably impacted park lands in an unsustainable manner.

4. ORDERED, that defendants will not arrest or threaten to arrest plaintiff's (pursuant to 'Additional Permit Conditions and Restrictions' issued by Sandra Alley (Complaint attachment 32) or any similar bureaucratic device) for constructing, assembling, or.repairing signs unless such activity has demonstrably impacted park lands in an unsustainable manner,

5. ORDERED, to maintain the status quo, and stem- the rising tide of frivolous regulations Aimed at restricting First Amendment rights, defendants will demonstrate to the Court a clear danger to public safety PRIOR to promulgating any new regulations aimed at restricting the size.of signs in Lafayette Park, or the, materials of which they may· be constructed. (Demands such as those made in "Ad Hoc White House Liaison Committee on President's Park Sign Inspection of Public Expression.' (Complaint attachment 31-31a) would not qualify under this Order.).

6. ORDERED that defendants will honor the terms and conditions of permits issued to plaintiffs, and will not, without plaintiffs' permission, revise those conditions confiscate plaintiffs' communication tools without clearly demonstrating that such revisions are required for some legitimate reason. (The June 6, 1981, October 10, 1984, md Hay 9, 1985 confiscation arid destruction of plaintiffs' permitted mobile communications structure would constitute a violation of this· Order.)

7. ORDERED that defendants ·will allow plaintiffs a mobile speaker's platform, fully enclosed from the elements for the protection of electronic equipment and other weather-sensitive communications materials. Plaintiffs stipulate that such structure will remain unlocked to facilitate inspection by defendants or their agents.

8. ORDERED, that defendants will not utilize 36 CFR 50.12 or 36 CPR 50.19(e)(9)(10) to restrict the use of portable signs or banners within the specifications of the regulations, on the White House sidewalk

9. ORDERED, that defendants recall the Oath of Office to uphold plaintiffs' Constitutional rights.

10. ORDERED, that defendants will read this entire Writ of Mandamus at the roll calls of all employees under their command.

11. ORDERED, that defendants will treat plaintiffs and all other peaceful demonstrators in Lafayette Park and on the White House sidewalk as welcome guests,

Dated this day of ____________ 1985.

Louis Oberdorfer, Judge
U.S. District Court


William Thomas,
Plaintiff, Pro Se
1440 N Street N$I, #410
Washington, DC 20005
(202) 462-3542

Happy Columbus Day.

Amended Complaint

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