WILLIAM THOMAS, et al Plaintiff Pro Se versus CA 84-3552 Judge Louis Oberdorfer UNITED STATES, et al Defendants
signs...." (Ibid at 7560.)
"If the regulations, when effective, have a greater
impact on one group of demonstrators, it is only because
those demonstrators are the ones causing the substantiaE
problems in the Park with large signs.,.." (Ibid.)
"Some commenters also suggested that restrictions an
demonstrations on the White House sidewalk make Lafayette
Park an even more important site for demonstrations directed
toward the White House. It is true that restrictions were
placed on the size, placement and construction of signs used
on the White House sidewalk in July of 1983 ... The
imposition of those regulations appears ... to be the reason
for the movement of large signs ... to Lafayette Park.:'
(Ibid st 7560.)
"Many of the commenters opposing the proposed
regulations ... take the position either that there is no
problem in Lafayette Park or that the problem can be handled
under existing regulations . The ACLU, for (just one)
example, stated that the Park Ceca has misrepresented the
current situation and that visitors to the Park find the
ongoing demonstrations to be a 'thrilling example of their
democracy in action.'
"Several commenters ... suggested a public meeting or
private negotiations concerning the rulemaking effort. It
would be inappropriate in this instance to have private
negotiations with any one individual or group. This
rulemaking has been thoroughly and intelligently discussed
in the media, through editorials, articles, and letters ta
the editor and thoughtful comments have been received from
all sides of the question." (Ibid at 7562.)
(Compare "FACTS" para. 2.)
to the Park. A letter writer from Newton, Kansas said:
11.)
form the basis of the proposed rules.
"First, the signs have never occupied a quarter to a
half of the interior space of the park, at most they occupy
less than one percent of the park's land, and are grouped
along one sidewalk.... There is ample space to stroll, or
have lunch, none of the park's flower gardens is affected by
the exercise of speech, nor are any of the chess tables
impaired in any way. Those wishing to gaze at the statues
of Revolutionary War heros, or enjoy the many other beauties
of the park may freely do so without coming in contact with
those who prefer to act on the American ideal of free
expression.
"Second, anyone who has been to the park can attest that
no 'Building boom' ever took place....
"Finally the existence of signs does not disrupt photo
opportunities, in fact there is more of a chance that those
strolling, eating lunch, or playing chess will block photo
vistas throughout most of the park. The only view in which
the signs may appear is one facing the White House from
immediately behind the signs....
"Even if the Park Service had compiled a compelling
factual case to support the regulations, the proposed rules
fall short of the constitutional requirements for
restrictions on speech." (Ad. Rec. III. A. 3.4.; compare
"FACTS" para. 14; compare photographs Ad. Rec. I.J.55, e.g,)
Now Exhibit 101-B Declaration Ellen Thomas filed this date, Trial Exhibit 146(f).)
signs. (Compare "FACTS" para. 21-22.)