CR No. 87-3290

Concepcion Picciotto,
Ellen Thomas,
Robert Dorrough, and William Thomas, Et. Al.

Plaintiffs pro se,


Donald Hodel,
James L. McDaniel,
the U.S. Park Police, and
the U.S. Secret Service,


Picciotto v. Hodel
Judge: J. Oberborfer

Petition, December 7, 1987, for preliminary injunction jurisdiction. 11pp.

Proposed Order, undated, temporarily restraining defendants from removing plaintiffs from Lafayette Park, enclosed with Petition. 1p.

Proposed Preliminary Injunction, December, 1987, against defendants and their agents intimidating plaintiffs. 1p.

Transcript, December 7, 1987, of proceedings in 87-3290, conversation Between the Court and Thomas. 3pp.

Memorandum, December 9, 1987, on plaintiff's application for a temporary restraining order. 2pp.

Motion, December 14, 1987, for Enlargement of Time for preliminary injunction. 2pp.

Proposed Order (unsigned), December, 1987, Granting motion for enlargement of Time. 1p.

Praecipe,(December 14, 1987, requesting Clerk of Court to enter Michael L. Martinez, DC Bar #347310, as counsel for defendants. 1p.

Order, December 28, 1987, Granting defendants' motion for Enlargment of Time by one week. 1p.

Motion, undated, to Dismiss by defentants. 1p.

Memorandum, undated, of law in support of defendants motion to dismiss. 5pp.

Proposed Order, undated, to dismiss. 1p.

Opposition, January 4, 1988, by Plaintiffs to Defendants' Motion to Dismiss. 7pp.

Proposed Order, undated, enjoining defendants from closing portions of Lafayette park without fulfilling requirements of 36 CFR 1.5 (c) (d) and (e). 1p.

Reply, January 7, 1988, of Defendants to Plaintiff's Opposition to the motion to dismiss. 3pp.

Motion, January 14, 1988, for leave to file an ammended porposed order. 1p.

Response, January 15, 1988, of Plaintiffs' to Defendants' reply to Plaintiffs' opposition to defendants' motion to dismiss. 2pp.

Motion, January 15, 1988 for leave to file an amended proposed order. 1p.

Motion, February, 1988, for leave to file out of time plaintiff's motion to reconsider. 1p.

Motion, February, 1988, to Reconsider action by granting government's motion to dismiss. 2pp.

Motion, February, 1988, for leave to refile plaintiffs' opposition to defendants' motion to dismiss. 2pp.

Motion (handwritten), March 8, 1988, for leave to file an handwritten original on yellow paper. 1p.

Motion (handwritten), March 8, 1988, for enlargement of Time. 3pp.


Defendants Exhibit 1; Notice, December 5, 1987, to public of closing southern portion of Lafayette park for short periods during the Reagan/Gorbachev Summit, December 7-10, 1987. Enclosed map showing portions to be closed.

Defendants Exhibit 2; Page, from Communist and Marxist Parties of the World, 1986.

Defendants Exhibit 3; Letter, June 6, 1985, From Thomas To Ronald W. Reagan.

Defendants Exhibit 4; Petition to the Hundredth Congress of the USA and to the Supreme Soviet (Congress) of the USSR.

Defendants Exhibit 5; Letter, December, 1987, to Mr and Mrs Gorbachev.

Defendants Exhibit 6; Declaration of Concepcion Picciotto (unsigned).

Defendants Exhibit 7; Declaration, December 7, 1987, of William Thomas (Unsigned).

Defendants Exhibit 8; Declaration of Robert Dorrough (unsigned).

Defendants Exhibit 9; Declaration of Ellen Thomas (unsigned).


Exhibit 1: Declaration, January 4, 1988, of Robert Dorrough as to events in Lafayette Park on December 8, 1987.

Exhibit 2: Page 41 of Crimes and Criminal Procedure stating amendments to 1984-Pub.L. 98-473 section 3056.

Exhibit 3: Article, December 12, 1987, from Washington Post, "Soviet Leader Stops in the Name of Glasnost."

Exhibit 4: Article, December 11, 1987, Los Angeles Times, "Gorbachev Handles Washington Like an Old Pol."

Exhibit 5: Article, December 19, 1987, Chicago Times, "Gorbachev Charms 'em."

Exhibit 6: Articles, December 11, 1987, USA Today, "Playing to the crowd, USA-style."; Philidelphia Inquirer, "Gorbachev halts limo to work crowd."

Exhibit 7: Article, December 11, 1987, Philidelphia Inquirer, "Leaders Defer 'Star WArs' Issue."

Exhibit 8: Regulation, National Park Service, Interior, section 1.5 Closures and public use limits.

Exhibit 9: Constitution of the Union of Soviet Socialist Republics, Articles 46-61.