Concepcion Picciotto,       )
Ellen Thomas,                )
Robert Dorrough, and         )       C.A. No. __________________
William Thomas, Et. Al.      )       Judge______________________
       Plaintiffs pro se     )
                             )
    v.                       )
                             )
Donald Hodel,                )
James L. McDaniel,           )
the U.S. Park Police, and    )
the U.S. Secret Service,     )
       Defendants.           )

I, Concepcion Picciotto, hereby declare under penalty of perjury that the following is true an correct to the best of my knowledge and understanding:

1. I have maintained a continuous presence on the White House sidewalk and in the southern portion of Lafayette Park since August, 1981, for the purpose of communicating the urgency of the global elimination of nuclear weapons.

2. During the course of my continuous presence I have been present on the occasions of scores of bisits to the White House by various Heads of State.

3. I never threatened the security of any person or impeded the passage of any person.

4. I have never before been excluded from the "route of access" of any "visiting Head of State," including passage by President Reagan.

5. I will not threaten the secutiry of Mr. Gorbachev, or to impede his passage.

___________________________