A. The Complaint
B. Declaration In Support of Request to Proceed in Forma Pauperis
C. Judge Wertherim, Order

FEB - 6 1986


Civil Action No. CA 1108-86

personally, and representing
1440 N St. N.W. Apt. 410
WASH. D.C. 20005


WASHINGTON TIMES Inc. by and through resident agents: BO HI PAK, ARNAUD DeBORCHGRAVE, and 3600 New York venue, N.E. Washington, D.C. DEFENDANTS

COMPLAINT - Civil Conspiracy (Intentional)

1. Jurisdiction of this court is founded on D.C. Code Annotated, 1973 edition, as amended, Sec. 11-921.

2, Plaintiffs are residents of the District of Columbia, appearing pro se

3. Defendant is a Corporate resident of the District of Columbia, with its principal place c business located in the District of Columbia.

4. THAT this is an action sounding in tortious conduct engaged in-by an employee of Defend? who was acting in the scope of his employment under the . authority of his superior to engage in a civil conspiracy with persons(identified and currently unidentified)to wrongfully and unlawfully abridge the civil rights OF Plaintiffs by means of premeditate violence for the unlawful purpose of intentionally inflicting emotional distress upon Plaintiffs, and for the further purpose of attempting to justify and aggrandize Defendant political opposition to Plaintiffs' high-profile 24-hour year-around anti-nuclear vigil being conducted by Plaintiffs in Lafayette Park under duly approved PERMIT of the U.S.P.S.

5. THAT in executing said civil conspiracy, Defendant's agent STEVE MASTY and several unknown individuals from a group calling itself Young Americans For Freedom had a meeting of the minds and decided to conduct a "raid" on Plaintiffs and their property for the agreed-upon purpose of striking fear into the hearts of Plaintiffs so that Plaintiffs might abandon their expressly permitted (U.S.P. Service Permits) and lawfully conducted activities in Lafayette Park. THAT, in fact, such a "raid" was unlawfully carried out on July 4, 1985 in the pre-dawn hours, calculated by the conspiritors to make "good" copy for the 4

6. THAT in pursuit of said "good" copy for its "patriotic" 4th of July weekend editions, the WASHINGTON TIMES virtually "cooked up" a story by sending MASTY to report on and participate in an assault on the Plaintiffs and their property as abovesaid, and to distort.

7. THAT Plaintiffs bring this cause to redress what they perceive to be a continuing menace to their lives and well-being in pursuit of their lawfully permitted activities in Lafayette Park, and to prevent any future-planned occurances which may again threaten Plaintiffs or others who may replace Plaintffs as anti-nuclear vigilists in the future.

8. THAT as a proximate result of the abovesaid actions, plaintiffs have been damaged by Defs.

Wherefore, Plaintiff demands judgment against Defendant in the sum of



with interest and costs. plus punitive damages

/S/W. Thomas_________
William Thomas pro se
Phone, [202] 544-6254
1440 N St N.W. Apt. 4 410
Washington, D.C. D C. 20005

William Thomas_______, being first duly sworn on oath deposes and says that the foregoing is a just and true statement of the amount owing by defendant to the plaintiff, exclusive of all set-offs and just grounds of defense.

/s/W. Thomas______________
(Plaintiff Agent)

Subscribed and sworn to before me this 6th day Of February 1986

/s/Bernice E. Stone
(Notary Public )
My Commission Expires December 14, 1987 1290

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