THOMAS v. REAGAN

USDC Cr. No. 84-3552

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS                 
           Plaintiff,          
                               
      vs.                      
                               
UNITED STATES OF AMERICA, et. al.          Civil Action No. 84-3552
          Defendants                        FILED
                                          JUL 29 1988
                                   CLERK, U.S. DISTRICT COURT
                                      DISTRICT OF COLUMBIA

NOTICE TO COUNSEL

This Court has requested and obtained through counsel for defendants copies of applications and related communications pertaining to demonstration permits plaintiffs have sought and rece ived from Department of the Interior officials in reference to plaintiffs' First Amendment activity in Lafayette Park. Copies of these records are attached. The parties may, on or before August 9, 1988, file comments on the question whether this Court may judicially notice the permit material.

(signed) Louis F. Oberdorfe
UNITED STATES DISTRICT JUDGE


OMB CLEARANCE NO:1024-0021
Expires 2/29/89

NATIONAL PARK SERVICE, NATIONAL CAPITAL REGION
APPLICATION FOR A PERMIT TO CONDUCT A DEMONSTRATION OR
SPECIAL EVENT IN PARK AREAS AND APPLICATION FOR A WAIVER
OF NUMERICAL LIMITATIONS ON DEMONSTRATIONS FOR
WHITE HOUSE SIDEWALK* AND/OR LAFAYETTE PARK

DEC. 18, 1987 - Date of this application

1. Individual and/or organization sponsor(3)

W. THOMAS and ELLEN THOMAS
Address(es) 1440 N ST. NW, #410 Washington, DC_ 20011
Telephone Nos.(include area code] Day(202)462-0757 Evening 462-0757

2. This is an application for a permit to conduct a
DEMONSTRATION XX
SPECIAL EVENT __ (For definitions, see instructions.)

3. This is an application for a WAIVER OF THE Numerical Limitations on certain demonstrations. Yes__ No X.(A waiver is required if it is expected that a demonstration on the White House Sidewalk */will include more than 750 participants or that a demonstration in Lafayette Park will include more than 3000 participants.)

4. Date(s) of proposed activity:
From 12-21-87 To 12-28-87
Time: Begin 00:01 (a.m.) (p.m.) Terminate: 24:00 (a.m.)(p.m.)

5. Location(s) of proposed activity.(Include assembly and dispersal areas.)
24 SO. FT. ON THE SOUTH SIDEWALK OF LAFAYETTE PARK. WEST OF THE CENTER PANEL

6. Purpose of proposed activfty.
TO PROMOTE AND DEMONSTRATE THE RESOLUTlON OF CONFLICT THROUGH PATIENCE, UNDERSTANDING, AND RERSON.

7. Estimated maximum number of participants. (If more than one park area is to be used, list numbers sepatately for each area.) THREE

8. Will cleanup people be provided for the area? XX yes __ no.
How will they be identified? By name (SEE Above para. 1)

9. Person(s) in charge of activity. (One person must be listed as in charge of the activity. If different individuals are to be in charge of various activities at different locations, each must be listed.) (The "White House Sidewalk" is the sidewalk between East and West Executive Avenues, an the south side of Pennsylvania Avenue N.W.)
Person in charge W. THOMAS
Address 1400 N Street NW, Apt #410, Washington, D.C. 20003
Telephone Nos. (Include atea code) Day 462-0757 Evening 462-0757

10. Plans for proposed activity. (Include a list of all principal speakets and the complete time schedule for the activity. Include proposed

1

route of any march or parade, and plans fot the orderly termination and dispersal of the proposed activity which might affect the regular flow of city traffic.)________________________________

We propose to demonstrate individual responsibility and moral commitment to our religious principle that "sin is to value one's own pleasure or comfort,above the life of another" by maintaining a continuous, 24-hour presence WITHOUT what might reasonably be considered living accommodations to illustrate that the value of a human being is best measured by the being's spirit (i.e. soul/mind) rather than its monetary net worth. We will seek and/or welcome public dialogue at all hours, day and night.

NOTE: Our "presence" will be "continuous" excepting we will leave the Park area to wash, launder our clothes, prepare food, store personal property, and perform all eliminatory and other biological bodily functions. None of the aforesaid functions will be performed in the Park. We may engage in short-term, intermittent, INVOLUNTARY sleep during the course of our presence, but only as nature demands.

11. (a) List all props, stages, round equipment, and other items to be provided by applicant/sponsor. (Include approximate number and size(s) of supports, standards, and handles; necgssary medical/sanitary facilities and other similar items.) ____________________

2 signs: 1 flag; 1 insulated bag per person (during cold weather, to be removed when not in use); literature (not to exceed 2,500 pieces at any one time); literature trays; one piece oi 20 mm. plastic (10 ft. x 12 ft.), pencils, pens, writing and editing materials (to be contained in one box measuring 4 in. x 6 in. x 18 in.) books (not to exceed 10); camera; tape recorder; umbrellas (1 per person); 1 water jug; 1 broom; 1 blanket per person to sit on; 1 plastic "Great Peace March: crate (12" x 12" x 18", approx.); no more food than might reasonably be consumed during a 24-hour period.

(b) If boxes, crates, coffins, or similar ltems will bc used, state whether they are to be carried opened ot closed, their proposed size, the materials constructed from, and their proposed contents and use.

SMALL SPEAKER'S PLATFORM

12. (a) Do yau have any reasan to believe or any informatian indicating that any individual, gtoup, or organization might seek to disrupt the activity for which this application is submitted? YES

(b) If YES, list each such individual, group, or organization, with information on as to each, including address and telephone numbers.

Washington TIMES (and/or the Unificatian Church), 3600 New York Avenue NE, Washington, D.C. Upon infarmation publiohed and from personal experience we believe this organ will place our form abave our substance and attempt to disrupt our activities by telling the public that we are ugly and "anti- American," because of editorial ideological opposition to the substance of our message.

Young Americans for Freedom, national headquarters in Wilmington, Delaware, precise local address currently unknown. Upon personal experience we believe members of this organization may resort to actual physical violence against us because of ideological opposition to the substance of our message.

Nevertheless, in spite of potential unpleasantness, we do not require any special protection or surveillance, convinced (from experience) that God, and our commitment to nonviolence as the only path to peace, protect us.

13. Marshals: (a) Will applicant/sponsor furnish marshals? - (Required for events of numerical limitations and for demonstration activities held simultaneously on White House sidewalk and Lafayette Park.) Yes __ No X . If YES how many marshals will be furnirhed?

(b) Persons(s] responsible for supervision of Marshats (for eaeh location): locatian(s) NOT APPLICABLE.

APPLICATION NOT VALID UNLESS SlGNED

Middle of the road
Position of person filing application

(signed) W. Thomas
Signature of person filing application

Day 462-0757 Evening Same
Telephone Nos. of person filing application

W. THOMAS
Typed or printed name of person filing application

1440 N St. NW #410 D.C. 20005
Address of person filing application



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