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 ROBERT DORROUGH RE
MARCH 23, 1987

I, Robert Dorrough, declare under penalty of perjury that the following is accurate and correct to the best of my knowledge:

1. On or about March 23, 1987, at about 6:00 am I was rousted by U.S. Park Police officer Hewick. "Wake up. Get up, Robert." He barked.

2. I observed him pulling and prodding two individuals, Scott Galindez, and Kayleen Purdy, who were reposing beside my signs. "Who are you." He asked. then he recognized Scott Galindez and began calling him by name.

3. Officer Hewick then walked to the center of the Park where Concepcion Picciotto has her display. I observed him rigging up a piece of blue plastic which Concepcion uses to cover her literature. I moved down to where Concepcion was in order to observe closer. when I arrived officer Hewick was engaged in a search of Concepcion's things.

4. Next he visited the other sites and began to search through everyone else's effects.

5. While officer Hewick was rooting around the demonstration of Sunrise I approached him and said: "Excuse me sir, but what is your probable cause?"

6. "I dont't need one." He said.

7. "I beg to differ, sir, but yes you do."

8. "That's where you're wrong." Officer Hewick insisted. "You're out here in the open. You have no expectation of privacy. I need no probable cause. If you had any understanding of the law you'd know that."

9. I walked back to my demonstration site, followed by officer Hewick, who quickly gave my material the once over. "You're alright." He said.

10. Kayleen Purdy had already departed. Then officer Hewick addressed Scott Galindez. "Scott are you part of this demonstration?"

11. "Yes." Scott replied.

12. "Good, I'm confiscating this." Officer Hewick replied, and grabbed a 24 inch by 18 inch sign which Scott had near his head.

13. Scott pleaded with him to return the sign, but to no avail.

14. Scott told me that it was 6:13 am.

Sworn to this ____ day of March, 1987

_________________________________

Robert Dorrough

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