THOMAS v. REAGAN
USDC Cr. No. 84-3552
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS, pro se,
Plaintiff,
v. Civil Action No. 84-3552
(Judge Louis Oberdorfer)
UNITED STATES, et al.,
Defendants.
FEDERAL DEFENDANTS' MOTION FOR JUDGMENT
ON THE ADMINISTRATIVE RECORD
The federal defendants, by and through their undersigned
counsel, hereby move pursuant to Fed. R. Civ. P. 7(b)(l) for
judgment on the administrative record insofar as the plaintiff
challenges the National Park Service's recently published
Lafayette Park regulation, 51 Fed. Reg. 7556 (March 5, 1986).
Reasons in support of this motion are set forth in the attached
memorandum of law which also opposes plaintiff's motion for
preliminary injunction. Also attached is a Statement of Material
Facts, which is submitted as an aid to the Court to help focus
1
the administrative record in this matter. That record was filed
with the Court on March 17, 1986. Finally a proposed order is
also attached.
Respectfully submitted,
JOSEPH E. DIGENOVA, DC BAR #073320
United States Attorney
ROYCE C. LAMBERTH, DC
Assistant United States Attorney
(signed)
JOHN D. BATES, DC
Assistant United States Attorney
(signed)
MICHAEL L. MARTINEZ, DC
Assistant United States Attorney
Case Listing --- Proposition One ---- Peace Park