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
PLAINTIFFS' RESPONSE TO THE COURT'S NOTICE TO COUNSEL
On July 28, 1988 this Court entered a Notice To Counsel
inviting the parties to "comment() on the question whether this
Court may judicially notice the permit material."
The records attached to the Court's Notice To Counsel are
certainly germaine to this matter and do merit serious considera-
tion, however plaintiffs would strongly object to any presumption
that those records are a complete or accurate representation of
all "applications and related communications pertaining to demon-
stration permits plaintiffs have sought and received from Depart-
ment of the Interior officials in reference to plaintiffs' First
Amendment activity in Lafayette Park." [1] Notice To Counsel.
With all due respect, plaintiffs would comment:
1. various agreements made in the applicatian are
unnecessarily restrictive, and needlessly hamper communicative
efforts (e.g., not more than 2,500 pieces of literature at any
one time, not more than 10 books, 4'x4' foot signs, three foot
attendence requirement, restrictions on speaker's platforms and
public address systems), and the Court should not assume that
[1 See, e.g., Complaint, filed, November 21, 1984, Exhibits 24,
30, 31, 35.,and paras. 93, 105, 106, 107, 108, and 117, also,
Amended Complaint, filed October 19, 1985, paras. 79r 84 and 90.
cf., Memorandum Opinion, Report & Recommendation of Magistrate
Arthur L. Burnett, filed, January 13, 1987 at pages 13 and 14.]
1
plaintiffs compliance with the provisions of this permit indicate
that they believe it is acceptable, necessary, or legal;
2. The Federal Register, March 5, 1988, included in the
material supplied by defendants' counsel, is a primary subject of
this action. SEE, Amended Complaint, pages 24 - 37, also, Oppo-
sition To Federal Defendant's Motion For Judgement On The Admin-
istrative Record, filed September 22, 1986;
3. the only reasons plaintiffs applied for this
specific permit was to illustrate their civility, and the fact
that the activities in which they had been engaged, and for which
they had been arrested, were perfectly permissable, and that the
defendants had been harassing plaintiffs for engaging in a
permissable activity.
(signed) W. Thomas
William Thomas, Plaintiff Pro Se
1440 N Street NW, #410, DC 20005
(202) 462-0757
CERTIFICATE OF SERVICE
I, William Thomas, hereby state that on this 5th day af
August, 1988, I senred copies of the foregoing PLAINTIFFS'
RESPONSE TO THE COURT'S NOTICE TO COUNSEL by hand at the offices
of:
AUSA Michael L. Martinez
Rm. 4822 Judiciary Center
555 4th Street, N.W.
Washington, D.C. 20001
D.C. Corporation Counsel
District Building
Pennsylvania Ave. N.W.
Washington, D.C.
William Thomas,Plaintiff Pro Se
Contents
Case Listing --- Proposition One ---- Peace Park