THOMAS v. REAGAN

USDC Cr. No. 84-3552

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

WILLIAM THOMAS, et al    
     Plaintiff Pro Se    
                         
versus                          CA 84-3552
                                Judge Louis Oberdorfer
UNITED STATES, et al     
     Defendants

DECLARATION OF WILLIAM THOMAS
REGARDING CITATION ISSUED BY OFFICER WARD
DECEMBER 22, 1986

I, William Thomas, plaintiff pro se in the above entitled action, hereby declare under penalty of perjury that the following is true and correct to the best of my knowledge:

1. On December 21, 1986 I arrived in Lafayette Park at approximately 2330 hrs.

2. According to the Washington Post, December 22, 1986, the temperature at that time was 32 degrees Farhenheit check sp.

3. At approximately 2345hrs I lay down on the sidewalk in a sleeping bag, next to my wife, Ellen Thomas, who was in another sleeping bag. We spoke for approximately fifteen minutes before I drifted off into a nap.

4. My nap continued until approximately 0130hrs when my attention was drawn a Park Police vehicle which, for no reason discernible to me, had halted next to the curb on the north side of Pennsylvania Avenue and sounded its siren.

5. At that point I lay on the sidewalk completely awake for another fourty-five minutes.

6. At approximately 0226hrs my attention was drawn by the sound of a police radio. Officer Ward appeared from behind one of my signs, handed me a citation, and said: "Mr. Thomas, your activities constitute a violation of the camping regulation." At that time Officer Ward was accompanied by Officer Covington.

7. At approximately 0315hrs, I left the park to urinate, as is my custom. I returned at approximately 0320 hrs, when I saw Concepcion Picciotto awake and sitting up. She said "hello" to me.

8. I remained totally awake until approximately 0345hrs, when I heard the sound of a car door slam. Upon hearing a slight commotion some distance to the east of where I was lying, I got to my feet to investigate. I arose in time to see a Park Police supervisor's car pulling away from the curb. I noticed Concepcion Picciotto was on her feet.

9. At approximately 0435hrs an individual, who identified himself as Park Police evidence technician Simonella, photographed Ellen and I. That individual was in the presence of Officer Ward, and two Park Police sergeants, whom I am unable to identify at this time.

Executed December 23, 1986.

____________________________________

William Thomas, Plaintiff Pro Se

1440 N Street, N.W. Apt. 410

Washington, D.C. 20005

(202)-462-3542

Contents

Case Listing --- Proposition One ---- Peace Park