UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

CONCEPCION PICCIOTTO, et. al.,
          Plaintiffs,

     v.                            Civil Action No. 87-3290-LFO

DONALD MODEL, et. al.,

MOTION FOR LEAVE TO FILE
AN AMENDED PROPOSED ORDER

Initially the defendants provided no legal authority for the contested action of closing a section of Lafayette Park.

After the Government finally referred to purported legal authority (36 CFR 1.5), plaintiffs' research indicated that the Government had clearly failed to fulfill the legal pre-requisites for the implementation of measures to close a public park.

In light of the defendants' tardy identification of legal authority, and plaintiffs pro se ignorance of the related law, plaintiffs now move for leave to file an amended proposed Order both to clarify the legal issues as plaintiffs perceive them, as well as to save the Court's time. Respectfully submitted,

William Thomas 203-012
Occoquan II, Dorm K-II
P.O. Box 85
Lorton, Virginia
22079

CERTIFICATE OF SERVICE

I, William Thomas, hereby certify that, on this 25th day of February, 1988, a copy of the foregoing Plaintiffs' Motion For Leave To File An Amended Proposed Order was served, by first class U.S. mail, postage pre-paid, upon AUSA Micheal Martinez, Judiciary Square, 555 4th Street, N.W., Washington, D.C., 20001.