9/30/88 Complaint CA 88-3130

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE and PHILIP JOSEPH         )
P.O. Box 27217                        )
Washington, D.C.  20038               )
                                      )
SUNRISE S. HARMONY,                   )
P.O. Box 27217                        )
Washington, D.C.  20038               )
                                      )
PEACE PARK ANTI-NUCLEAR VIGIL,        )  
1440 N Street, N.W.  Apt. 410         )
Washington, D.C.  20085, and          )
                                      )
THE PEOPLE OF THE UNITED STATES,      )
     Plaintiffs, Pro Se               )
                                      )   CA 88-_____________
versus                                )
                                      )   Judge _____________
RONALD WILSON REAGAN,                 )
1600 Pennsylvania Avenue, N.W.        )
Washington, D.C.,                     )    COMPLAINT 
                                      )
OFFICE OF MANAGEMENT AND BUDGET.      )    CLASS ACTION
Old Executive Office Building         )
1602 Pennsylvania Avenue, N.W.        )    JURY TRIAL DEMANDED
Washington, D.C.,                     )
                                      )
DONALD HODEL,                         )
Interior Department                   )
18th and D Streets, N.W.              )
Washington, D.C.                      )
                                      )
RICHARD ROBBINS,                      )
Interior Department                   )
18th and D Streets, N.W.              )
Washington, D.C.                      )
                                      )
RANDY MYERS,                          )
Interior Department                   )
18th and D Streets, N.W.              )
Washington, D.C.                      )
                                      )
MANUS J. FISH                         )
1100 Ohio Drive, S.W.                 )
Washington, D.C.,                     )
                                      )
JAMES LINDSEY                         )
1100 Ohio Drive, S.W.                 )
Washington, D.C.,                     )
                                      )
SANDRA ALLEY                          )
1100 Ohio Drive, S.W.                 )
Washington, D.C.,                     )
                                      )
FRAN WIGGLESWORTH,                    )
1100 Ohio Drive, S.W.                 )
Washington, D.C.,                     )
                                      )
RICK MERRIMAN,                        )
1100 Ohio Drive, S.W.                 )
Washington, D.C.,                     )
                                      )
LYNN HERRING,                         )
1100 Ohio Drive, S.W.                 )
Washington, D.C.                      )
                                      )
DEPUTY CHIEF LANGSTROM,               )
1100 Ohio Drive, S.W.                 )
Washington, D.C.                      )
                                      )
CAPTAIN BARRETT,                      )
1100 Ohio Drive, S.W.                 )
Washington, D.C.,                     )
                                      )
VARIOUS KNOWN AND UNKNOWN             )
     GOVERNMENT AGENTS,               )
                                      )
     Defendants                       )
______________________________________)

COMPLAINT

JURISDICTION

Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1970), Butz v. Economou, 438 U.S. 479 (1978), Davis v. Passman, 442 U.S. 228, and 42 USC Sections 1985(3), and 1986.

VENUE

28 USC Sections 1331, and 1343.

PARTIES

PLAINTIFF

1. Mary Huddle is an adult human being, abiding within the legal jurisdiction of the United States of America, Federal District of Columbia.

2. Philip Joseph is an adult human being, abiding within the legal jurisdiction of the United States of America, Federal District of Columbia.

3. Sunrise S. Harmony is an adult human being, abiding within

the legal jurisdiction of the United States of America, Federal District of Columbia.

4. PEACE PARK ANTI-NUCLEAR VIGIL is a four-and-a-half year effort by William and Ellen Thomas to maintain a continuous presence in Lafayette (Peace) Park, on the north side of the Presidential mansion within the Federal District of Columbia.

5. THE PEOPLE OF THE UNITED STATES are named by virtue of the rights, privileges, and immunities guaranteed by the First, Fourth, Fifth, Ninth, and Fourteenth Amendments to the Constitution of the United States of America under the theory that when the government acts to suppress the guaranteed rights, privileges, and immunities of any individual under color of regulation, the liberty of all individuals is jeopardized under color of the same regulation.

CLASS ACTION

6. The class is all individuals or groups under twenty-five, as defined in 36 CFR 7.97 (g)(2)(i). Any citizen of the United States might become a member of this class by virtue of attempts to exercise the rights, privileges or immunities which have been denied plaintiffs under color of the wrongful regulatory scheme alleged herein.

DEFENDANTS

7. Ronald Reagan is President of the United States of America, sued in both his personal and official capacities.

8. OFFICE OF MANAGEMENT AND BUDGET is an administrative agency which owe plaintiffs, as members of the public, a duty pursuant to Executive Order 12291.

9. Donald Hodel is the Secretary of the United States Interior Department.

10. Richard Robbins is an Assistant Solicitor with the Office of Fish and Wildlife, United States Interior Department.

11. Randy Myers is an Assistant Solicitor with the Office of Fish and Wildlife, United States Interior Department.

12. Manus J. Fish is the Director of the National Park Service, National Capitol Region.

13. James Lindsey is presently employed with the National Park Service, National Capitol Region, and during the period in which he is named in this complaint was Deputy Chief of the U.S. Park Police.

14. Sandra Alley is public relations Director for the National Park Service, National Capitol Region.

15. Fran Wigglesworth is with the Permits division of the National Park Service.

16. Rick Merriman is with the Permits division of the National Park Service.

17. Lynn Herring is the Chief of the United States Park Police.

18. Captain Burrett is an agent of the United States Park Police, used to implement administrative policy.

19. VARIOUS KNOWN AND UNKNOWN AGENTS. To save time and energy for all parties, rather than charging all official participants for their part in depriving plaintiffs' civil rights through the specific actions by which plaintiffs suffered injury, plaintiffs suggest that the many individual agents who acted to manifest the alleged conspiracy simply be judged by their own words and actions as material witnesses in this suit. Under the theory of this Complaint liability for the actions of these agents -- some of whom may have been motivated by personal

animus, others of whom may have been "just following orders" -- should be laid at the feet of the agencies by which the individual agents are employed and which uttered the words under color of which each agent acted.

NATURE OF ACTION

20. This claim asserts that the defendants have engaged in a concerted effort to organize and execute totalitarian police state tactics under color of an intricate regulatory scheme, with the intent to deprive plaintiffs of various rights privileges, and immunities which defendants knew, or should have known, were guaranteed plaintiffs under the Constitution of this nation. In furtherance of the alleged plot to deprive plaintiffs of Constitutional protection, certain defendants organized a complex and far-reaching plan to evade certain constitutional safe-guards provided for in the Administrative Procedures Act of Title 5 USC. The "various known and unknown government agents" performed the actions necessary to further the alleged conspiracy. It is alleged that the animus of defendants' alleged conspiracy was to suppress the exercise of the primary tenet of plaintiffs' religion, and to interrupt the expression of plaintiffs' moral opposition to the defendants' personal power play of Peace Through Strength by harassment, threats, intimidation, defamation, or imprisonment. As a direct and proximate result of the alleged scheme plaintiffs have collectively suffered the common law torts of assault and false arrest, false imprisonment, seizure of property, intentional infliction of emotional distress, as well as deprivation of due process and the exercise of their freedoms of religion, communication, and association in violation of the First, Fifth, Sixth, Ninth, and Fourteenth Amendments to the

Constitution of the United States of America, in violation of 42 USC 1985(3), and 1986. It is finally alleged that defendants' heavy-handed abuse of power would constitute the crimes of treason and sedition.

FACTS

21. All named plaintiffs share certain circumstances and beliefs, including but not limited to:

a) Each plaintiff arrived in Lafayette Park without pre-arrangement with any other plaintiff.

b) The motive of each plaintiff in focusing his or her energies to the geographical area of Lafayette Park was to conform his or her actions to a similar religious discipline.

c) All plaintiffs agree in principle that Christ is "the way, the Truth and the light," and attempt in their own lives, to the best of their abilities, to emulate Jesus' example.

d) Central to the religious discipline of each plaintiff is the concept that "one cannot serve two masters, one cannot serve God and mammon."

e) All plaintiffs share the belief that "mammon" is most universally represented by "money", and that energy spent in pursuit of money is an affront to God.

f) All plaintiffs also share the belief that the primary attributes of God are "Life" and "Love," view the antithetical attributes of "death" and "hate" as the opposite, and that they have a God-given duty to "spread this Gospel to every living creature."

g) All plaintiffs agree in fact that the first among laws is "to love the Lord God with all one's heart, soul, mind, and strength," and that "if one does not love one's neighber, who one has seen, then one cannot love God, who one has not seen."

h) All plaintiffs agree that force, violence, threats, and intimidation are tools of the anti-christ which cannot be employed to righteously resolve differences of opinion but which are only used to impose the will of one upon another, or to suppress freedom.

i) All plaintiffs agree that peace on earth can be achieved only by resolving differences of opinion through compassion, reasoning, communication.

22. On June 3, 1981, in the form of a pamphlet, plaintiff

Thomas issued "Manifesto of Independence: a fast for life, liberty and the pursuit of happiness" (Exhibit 1), explaining the reason for his presence on the White House sidewalk. This statement has been handed to thousands of tourists and citizens, officials of the U.S. Park Police, and, upon request, officials of the U.S. Secret Service, Executive Protective Branch.

23. The 36 CFR Section 7.96 (g)(i) defines "demonstration" as including "vigils or religious services and all other like forms of communication or expression of views or grievances ... which has the effect, intent, or propensity to draw a crowd or onlookers."

24. 24-hour, continuous vigils are permitted under NPS regulations.

25. Over the years plaintiffs have passed out printed material, and engaged in dialogue with passersby. Prior to the promulgation of 36 CFR 50.19(e)(11)(12) large, weather-proof signs containing succinct messages, clearly visible to motorists, pedestrians, tourists exiting the White House, from inside the White House, and which required no facilitation from the government, were the only method of mass communication, or attracting a crowd or onlookers, that were available to these plaintiffs. Subsequent to the promulgation of 36 CFR 50.19(e)(11)(12) plaintiffs have been deprived of any method of mass communication.

26. Beginning in July 1981 and continuing to the present time, various officials of the U.S. Department of Interior, U.S. Park Police, the National Park Service, Secret Service, D.C. Metropolitan Police Department, and the White House, acting under color of various federal and District of Columbia police regulations,

some in existence prior to that date, some promulgated since that date, have intentionally and deliberately acted in a manner which has had the effect of jeoprodizing the liberty of every individual within the legal jurisdiction of the United States, and depriving these plaintiffs of constitutionally protected rights.

27. On July 6, 1981 Thomas was arrested while demonstrating. Charges were dropped.

28. On November 27, 1981 Thomas was arrested while demonstrating. Charges were dropped.

29. On or about December 1, 1981 Thomas was arrested and removed from the White House area. No charges were lodged.

30. On December 12, 1981 Thomas was arrested and incarcerated. Charges were dropped.

31. On or about June 13, 1982 Thomas was arrested and incarcerated for an "unlawful structure" on the white House sidewalk. Charges were dropped.

32. On or about June 21, 1982 two of Thomas' signs were confiscated. Charges were dropped.

33. On November 11, 1982 Thomas was arrested and incarcerated during a demonstration. Charges were dropped.

34. On December 9, 1982 and on numerous other occasions government agents interfered with Thomas' display of signs, when no valid regulations authorized such interference.

35. On January 13, 1983 James Watt, who reported directly to defendant Reagan, issued a memorandum stating his intent to ban "protests and demonstrations" from Lafayette Park and the White House sidewalk, and require that they take place on the Ellipse. Exhibit 2.

36. On or about March 11, 1983 various officials seized Thomas' signs even though there existed no legal authority for them to do so.

37. On March 11, 1983 Thomas was arrested under color of "unlawful structure." Charges were dropped.

38. On March 15, 1983 Thomas was assaulted by a Metropolitan police officer, and arrested under color of disorderly conduct.

39. On April 27, 1983 Thomas was arrested under color of a newly-promulgated regulation which was later withdrawn. Charges were dismissed.

40. On May 3, 1983, in support of 36 CFR 50.19(e)(9)(10), Mr. Lindsey, in consort with others, gave, according to USDC J. Bryant, "incredible" testimony, under oath, before a Federal District Court for this District.

41. On May 5, 1983 Thomas was arrested under color of "unlawful entry." Charges were dismissed after Secret Service destroyed exculpatory evidence.

42. On June 17, 1983 various defendants acted in consort to publish 36 CFR 50.19(e)(9)(10) in the Federal Register.

43. On July 1, 1983 Thomas was assaulted by a Park Police officer.

44. During December, 1983 various defendants gave, again in the words of J. Bryant, "incredible" testimony at trial in support of 36 CFR 50.19(e)(9)(10).

45. On or about January 31, 1984 Thomas was arrested under color of "camping". Plaintiff's presentment to the court was delayed without cause. Charges were dismissed.

46. On or about June 6, 1984 the Thomases were assaulted, arrested and incarcerated under color of "camping," and

"assault." Plaintiffs' presentment to the court was delayed without cause. The Thomases' signs were seized and later found destroyed at the USPP property office. Camera and photographic evidence were seized by officer Haynes and subsequently "lost"; film was destroyed. Acquitted at trial.

47. On or about June 23, 1984 the Thomases were arrested and incarcerated under color of "camping," and some of their signs were destroyed. Plaintiffs' presentment to the court was delayed without cause. Charges were dropped,

48. On or about September 10, 1984, defendant Sandra Alley issued and distributed a memorandum arbitrarily proscribing various of plaintiffs' expressive activities.

49. On October 10, 1984 the Thomases' NPS-permitted mobile communication speaker's platform was seized, along with at least two other signs, and damaged.

50. On October 10, 1984 Thomas was incarcerated and denied the right to post collateral.

51. On October 15, 1984 three cloth banners were seized and damaged. No charges were lodged.

52. On May 9, 1985 the Thomases' NPS-permitted mobile speaker's platform was seized.

53. On May 9, 1985 Ellen Thomas was arrested. Charges were dismissed.

54. On or about October 11, 1985, Thomas was arrested for disorderly conduct. Charges were dropped.

55. On June 8, 1985, a sign was confiscated from the Thomases. Charges were dropped

56. On and before March 5, 1986 various NPS and DOI officials acted in concert to publish 36 CFR 50.19(e)(11)(12) in the

Federal Register.

57. On or about November 10, 1986, in Lafayette Park, Lieutenant Hugh Irwin assaulted Thomas and caused his false imprisonment under color of 36 CFR 50.19(e)(11)(12). Charges were dismissed.

58. On or about March 20, 1987 Lt. Hugh Irwin interfered with demonstration activities being conducted under a duly authorized permit from the National Park Service.

59. Routinely Park Police officers have demanded identification from demonstrators for no apparent reason.

60. On numerous occasions plaintiffs' demonstration activities have been photographed by members of the Park Police.

61. Various government agents have given false information to the press which has been detrimental to plaintiffs.

62. Repeatedly, and in good faith, plaintiffs have tried to reason with various Park Service officials so that they might effectively communicate their message while complying with the applicable regulations.

63. On some occasions, not enumerated in this Complaint, arrests of these plaintiffs have resulted in conviction at bench trials. To the best of plaintiffs' belief, every instance (with the possible exception of convictions of Thomas and Ellen Thomas for "attachment" and "general injury to a tree") that a criminal conviction has resulted, that conviction was predicated upon (a) a regulation which was enacted pursuant to perjurious testimony by government officials, (b) an official misrepresentation to the Court of a factual situation, and/or (c) less than a complete presentation of the complete factual situation at issue.

64. On or about September 30, 1987, in Lafayette Park,

Officer Covington, without probable cause, issued plaintiff Philip Joseph Park Police Citation Violation Notice, and confiscated a small stool from plaintiff.

65. During December, 1987 various Park Police officials arrested Philip Joseph in Lafayette Park without probable cause.

66. On or about June 20, 1988, in Lafayette Park, Officer Waite physically assaulted Joseph, resulting in physical and psychological injury to plaintiff.

67. Officer Waite, with the consent of an unidentified U.S. Park Police lieutenant, then arrested the plaintiff Joseph, placed him in handcuffs, and incarcerated him. Charges were dropped.

68. On September 9, 1988 plaintiffs Mary Huddle and Philip Joseph applied for a permit from the NPS that would allow them to distribute food and blankets to homeless people. While the NPS did issue the permit, plaintiffs were warned that if they conducted the proposed activities they would be in violation of the "camping" and "sign size" regulations.

69. Although exempted from Permit requirements, in an effort to establish parameters within which to conduct their activities in Lafayette Park without incurring the wrath of and avoid harassment from the police, each of the plaintiffs has applied for and been granted permits from the NPS. Exhibits 3, 4, and 5. Despite the fact that plaintiffs have remained within the limits of their permits they continue to be harassed, photographed, threatened and one even arrested by the Park Police.

ALLEGATIONS

70. Plaintiffs allege that the defendants' shared ideological concepts have animated them in concerted action against

all plaintiffs with the intent and for the purpose of suppressing plaintiffs in their exercise and communication of religious beliefs and principles.

7l. Specifically it is alleged that Mr. Ronald Reagan and Mr. Donald Hodel (and Mr. Hodel's predecessors, James Watt and William Clark) have shared very similar perceptions of reality on key issues of broad public concern - including, but not limited to, the administration of lethal force, the "morality" of nuclear weapons, the "morality" of nuclear weapons vis-a-vis "God's Will/God's Law," the relative importance of "national security" and economic/human value systems, as well as the use of intimidation, harassment, threats and coercion as implements of policy.

72. Likewise, it is alleged that each of the named defendants shared perceptions of reality similar to those of defendants Reagan and Hodel on the aforesaid issues of broad public, ideological, religious, and moral concern; including, but not limited to:

a) That world, or social, order can be imposed through force, violence, threats, and the infliction of pain and suffering upon human beings.

b) That reference to the concept of world, or social, order through the imposition of force, violence, threats, and the infliction of physical or emotional pain and suffering upon human beings by the euphemism of "Peace Through Strength" mitigates the obvious immorality and innate evil of the concept.

73. Certainly, plaintiffs believe, it is likely that some of the individual agents who performed the actual arrests, assaults, seizures, and other actions which caused plaintiffs injury may have been motivated by personal animus. That factor is unimportant. What is important is that President Reagan allowed, if not engineered, a situation which effectively

eliminated, under color of regulations, the time-honored legal principles which had previously protected individuals engaged in expresssive activity from the arbitrary abuse of police power. One can only infer that President Reagan permitted or planned such a climate to shield his PERSONAL philosophy of Peace through Strength from critical attack.

74. It is alleged that Mr. Ronald Reagan and Mr. Donald Hodel have shared very similar perceptions of reality on key issues of broad public concern - including, but not limited to, the administration of lethal force, the "morality" of nuclear weapons, the "morality" of nuclear weapons vis-a-vis "God's Will," the importance of "national security," and economic/human value systems.

75. Likewise, it is alleged that each of the named defendants shared perceptions of reality similar to those of defendants Reagan and Hodel on the aforesaid issues of broad public, religious, and moral concern.

76. Unfortunately, it is alleged that both Mr. Reagan and Mr. Hodel directed or assented to a regulatory scheme which was intended to circumvent numerous provisions in the Constitution of the United States of America -- of which they knew, or certainly should have known -- for the purpose of subjecting individuals to an authoritarian standard of religious (personal), political (official) ideals.

77. Subsequently, plaintiffs allege, Mr. Reagan and Mr. Hodel, and Mr. Hodel's two immediate predecessors in office, acted to promote an atmosphere conducive to arbitrary, capricious, and hostile regulatory enforcement, and particularly in Lafayette Park and in front of the White House, armed by the

lethal force of the United States Park Police and Secret Service, acting under color of what defendants knew to have been excessive, unnecessary regulations.

78. With the intent to create the judicial illusion that the allegedly excessive, unnecessary regulations actually served a "substantial government interest," various government agents gave false testimony under oath, supported by fabricated photographic evidence, for the purpose of justifying 36 CFR 50.19(e)(9)(10).

79. Similarly, for the purpose of justifying 36 CFR 50.19(e)(11)(12) various defendants acted to create an administrative illusion in the Federal Register of August 20, 1985, and again on March 5, 1986.

80. Finally, incorporating by reference paragraphs 70 - 75 above, it is alleged that whether the VARIOUS KNOWN AND UNKNOWN AGENTS were motivated by similar religious (personal), political (official) prejudices, is unimportant to this case in as much as those individuals merely acted out the designs of the named defendants.

CAUSES OF ACTION

8l. By creating an atmosphere in which individuals would be deprived of the protection of the most Fundamental Laws of the United States of America, defendants have wielded Title 36 CFR as a sledgehammer to fracture the foundation of civilization, thus jeopardizing the liberties of each and every person within the legal jurisdiction of the United States and, therefore the entire structure of democracy. Personally, plaintiffs are opposed to the notion that punishment might bear any relation to justice. However, in deference to the traditions of the Court, in the event a jury finds that the allegations of this Complaint are

valid, and further assuming that the function of this Court is to deter threats to Constitutional government through criminal proceedings, defendants should be subject to criminal prosecution under those provisions of the United States Code which prohibit treason and sedition.

82. Incorporating by reference paragraphs 27-3l, 33, 37, 39, 4l, 45-47, 53, 54, 57, 65, and 67, plaintiffs claim that they have suffered the common law tort of false arrest.

83. Incorporating by reference paragraphs 30, 3l, 33, 46, 47, 50, and 67, plaintiffs claim that they have suffered the common law tort of false imprisonment.

84. Incorporating by reference paragraphs 45-47, plaintiffs claim that the several incidents of intentional delay in presenting plaintiffs to a magistrate after arrest, thus resulting in several days of incarceration violated plaintiffs' Fourth and Fifth Amendment right to be brought before a judicial officer without unnecessary delay.

85. Incorporating by reference paragraphs 32, 36, 46, 47, 49, 5l, 52, 55, and 64, plaintiffs claim that they have suffered unwarranted seizure, destruction of, or failure to return literature, tools, signs, and camera; no receipts were provided in any of the seizures; undue delay in returning property to plaintiffs, and careless handling of plaintiffs' property.

86. Incorporating by reference paragraphs 40, 44, 6l, and 63, plaintiffs claim that they have suffered from false testimony and/or obstruction of justice, and false statements to the press for the purpose of maligning plaintiffs.

87. Incorporating by reference paragraphs 38, 43, 46, 57 and 66, plaintiffs claim that they have suffered from assault

inflicted by various named and unnamed defendants.

88. Incorporating by reference paragraphs 4l and 46, plaintiffs claim that they have suffered the destruction of evidence central to their defense against false arrest.

89. Incorporating by reference paragraphs 34, 58, 59, 60, 68 and 69, plaintiffs claim that they have suffered ongoing police harassment and intimidation.

90. Incorporating by reference paragraphs 35, 39, 42, 48, and 56, plaintiffs claim that they have been victims of an arbitrary abuse of regulatory power intended to thwart the articulation of ideas critical to the personal policies of government officials. SUPRA, paragraphs 70 through 80.

9l. Incorporating by reference paragraphs 26 thru 69, plaintiffs claim that they have suffered the common law tort of intentional infliction of emotional distress.

92. Incorporating by reference paragraphs 26 thru 80, plaintiffs claim that all named defendants have been actors in a concerted scheme which was designed to deny or hamper the exercise of constitutional rights to a class of persons, in violation of 42 USC 1985(3).

93. Incorporating by reference paragraphs 26 thru 69 plaintiffs claim that they have been direct victims of the scheme alleged in paragraph 92 and have proximately suffered abridgement of guarantees under the First, Fifth, Sixth, Ninth, and Fourteenth Amendments to the Constitution of the United States of America, in violation of 42 USC 1985(3), and 1986.

RELIEF

WHEREFORE plaintiffs pray an award of punitive and compensatory damages against each defendant in such sum as deemed

appropriate to insure plaintiffs' right to a trial by jury, and to send a symbolic message to those who might be tempted to abuse the authority of their office for PERSONAL or political gain that the Courts of this land will not tolerate the arbitrary desecration of principles intended by the Founding Fathers as safeguards against the force of despotic government.

Plaintiffs also pray the Court to fashion an injunction directing defendants to formulate a supervisory policy which will insure that individuals are not subjected to the arbitrary or capricious deprivation of Constitutional rights under color of 36 CFR in Lafayette Park or in front of the White House.

Respectfully submitted,

_____________________________
Mary Huddle
P.O. Box 27217
Washington, D.C. 20038

_____________________________
Philip Joseph, Pro Se
P.O. Box 27217
Washington, D.C. 20038

_____________________________
Sunrise S. Harmony
P.O. Box 27217
Washington, D.C. 20038

_____________________________
Ellen Thomas
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757

_____________________________
William Thomas
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757