Plaintiffs, Pro Se               )   
                                      )   CA 88-_____________
versus                                )   
                                      )   Judge _____________
RONALD WILSON REAGAN, et al,          )  
     Defendants                       )


I, William Thomas, a plaintiff, pro se, in the above entitled action, hereby declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection:

1. Animated by my religious conviction that indiscriminate mass murder, even in the name of security for the United States, isa sin, I believe that God has directed me to commit my life to solving what I believe to be the issue of broadest public con-cern: "Peace Through Understanding," "Peace Through Reason," or "Peace Through love,"

2. Drawing my hope from the twenty-ninth chapter of Isaiahand the story of Jonah, I was drawn to commence a continuous presence outside the White House to reproach policies of force and violence.

3. On June 3, 1981, I began an expressive action on the south sidewalk of Pennsylvania Avenue, opposite Lafayette Park. At that time I had two small cardboard signs. One sign read: "Wanted Wisdom and Honesty," the other sign read "Hypocrisy Stinks."

4. My intent with regard to that action was to communicate my opinion that "moral perfection is impossible for a member of an immoral nation-state," and to "encourage those who understand the meaning of my words to gather at the White House to pray for Peace, Sanity, and an End to War in illustration of the Ideals of non-violence," and to encourage "Life, liberty, and the pursuit of happiness." Exhibit 1.

5. During this period my primary methods for drawing attention to the issues I seek to address have been signs and symbolic actions. Because I am indigent these are virtually the only methods available by which to effect the expression of my opinions to the public.

6. I cannot deny that certain things I have done might be considered somewhat unusual, or even to some, perhaps, disturbing. However none of the actions during my activities in Lafayette Park since 1981 have been intended to harm individuals or property, and those actions merely served the basic prerequisite of communication, namely "attract(ing) a crowd or onlookers." SEE, 36 CFR 9.7(g)(i). In fact my presence has not resulted in any demonstrable impacts which the area of the Park has been unable to sustain, or material damage to the Park. On the contrary, each of my actions has been intended, to the best of my ability, to effect benefits for individuals and resources. At all times during the course of my demonstration activities I have attempted to modify my behavior so as to comply with the regulations to the best of my understanding.

7. The symbolic aim of my continuous reproachful presence on the north side the White House has been to illustrate the urgent need for personal responsibility, commitment, and even sacrifice to achieve a nuclear weapons-free world. To this end I have voluntarily forsaken enjoyment of many modern amenities of life -- including shelter and various other living accommoda-tions. Moreover, the practical aim of my continuous re-proachful presence has been to be available on a 24-hour-a-day basis in order to communicate my ideas, opinions, suggestions and theories, free of charge to any who ask, hoping to identify the problems which plague human society and, if only by identi-fying the problems, help in some degree to solve them.

8. Over the period many individuals other than the named plaintiffs in this action have adopted some of my methods of communication at the same location. Depending, at least to some degree, upon the conviction of the individual expressor to the truth of the opinion expressed, and upon the individual capacity for tolerating the frequent harassment at the hands of defendants and their agents, those who adopted my methods have remained in Lafayette Park for varying lengths of time.

9. On July 6, 1981 I was arrested while demonstrating. Charges were dropped.

10. On numerous occasions in November of 1981 my demon-stration activities on the White House sidewalk were photographed by members of the Park Police.

11. On November 27, 1981 I was arrested while demonstrat-ing. Charges were dropped.

12. On or about December 1, 1981 I was taken into custody by Officer Pamela (now Rose-Hay) Jackson and driven by officer Jacqueline Anderson, in a Park Police cruiser, to the U.S. Park Police District One sub-station, at ll00 Ohio Drive S.W..

13. After being held for some time at the sub-station, I was taken out of the sub-station and driven, by Officers Anderson and Jackson, in a Park Police transport vehicle, to, as best I was able to ascertain, the intersection of 30th and Southern Streets, S.E. At that location, and in the very early morning hours, the officers stopped the vehicle, opened the door to the chamber in which I had been locked, and told me to get out.

14. Initially I refused to get out of the vehicle. I observed to the officers that this was not the area in which I had been taken into custody, and that I had no desire to be in the area to which they had brought me. I demanded that the officers return me to Lafayette Park.

15. Officer Anderson told me that I couldn't return to that location because "the president and Mrs. Reagan live there." The officer again ordered me to leave the transport vehicle.

16. I again refused, demanding that I be taken to the N.W. section of the city.

17. Officer Anderson told me that if I didn't get out of her transport vehicle she would call for reenforcements, and have me removed.

18. Officer Anderson later told me that she had been given orders to drive me to a distant location.

19. On December 12, 1981 I was arrested while demonstrat-ing. I spent two weeks in D.C. Jail. Charges were dropped.

20. After those several arrests I tried to communicate with officials, to no avail. I hung myself by the wrists from a light-post in front of the White House to protest that fact.

21. Rather than respond, agents of the Secret Service gave false information to the press, claiming I had been sent to St. Elizabeth's Hospital for mental observation, resulting in embarassment and public defamation to me, and my actions.

22. Prior to the initial enforcement of 36 CFR 7.96 (formerly 36 CFR 50.27), Park Police private William Wolz testi-fied that during the period of these arrests Park Police officers had been given instructions to "arrest people on the White House sidewalk for trespassing, unlawful entry, and maybe a couple of other charges."

23. After each incident, however, I renewed my communica-tive efforts. Defendants were stymied in their attempts to suppress my First Amendment activity under color of "trespas-sing, unlawful entry, and maybe a couple of other charges," until the Community for Creative Non-Violence seized on the idea of a continuous vigil, but expanded that idea to include shelter.

24. Ex-Chief of the Executive Protective Branch Jerry Parr testified that because the Secret Service saw "signs on the White House sidewalk" as "the wave of the future," there were meetings between the Secret Service and "individuals and legal people from Interior and the Park Police to work out some kind of an arrange-ment" during the drafting of the camping regulation.

25. Defendant Robbins has also testified under oath that the U.S. Secret Service, U.S. Park Police, Interior Department, and National Park Service had concerns with the "situation on the White House sidewalk" as early as November 1981.

26. On or about June 13, 1982 I was arrested and incarce-rated for an "unlawful structure" on the White House sidewalk. Charges were dropped.

27. Despite very specific representations by the NPS and DOI with respect to the intent and proposed enforcement of 36 CFR 50.27, and the fact that, under those representations my contin-uous presence in Lafayette would not have been affected, Mr. Fish, without "good cause," suspended the thirty-day delay of effec-tiveness provided for in 5 USC 553, and the regu-lation was expedi-tiously, selectively, and arbitrarily enforced against me in the absence of any "good cause."

28. On or about June 21, 1982 private Jack Guentz confis-cated two of my signs from the White House sidewalk.

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

30. On December 9, 1982 and on numerous other occasions before and since that time, officers of the U.S. Secret Service Executive Protective Branch, Uniformed Division, kicked down signs which I had leaned against the White House fence. This was done in 1982 when no valid regulations then existed to permit this interference of my display of signs against the White House fence. During the course of their sign kicking and on numerous other occasions, the offending agents addressed me by such derog-atory names as "dirt ball" and "scumbag."

31. On January 13, 1983, James Watt,then Secretary of Interior, issued a memorandum (Exhibit 2) to Moody Tidwell. That memorandum was prompted by my legitimate demonstration activities on the White House sidewalk, and remains as an indica-tion of defendants' official policy and stated intent with re-spect to my continuous presence in the Park and my effective but harmless communications media.

32. On or about March 7, 1983 defendant Robbins met with Secretary Watt to discuss developments with respect to his memo of January 13th.

33. On or about March 11, 1983 defendant Robbins success-fully supervised a concerted effort between the U.S. Park Police, the U.S. Secret Service, and officials of the D.C. Metro-politan Police Force to remove my legitimate signs from the White House sidewalk, and the city of Washington, D.C., even though there existed no legal authority for them to do so.

34. On March 11, 1983 private J.R. James arrested me and caused my incarceration under color of "unlawful structure." Charges were dropped.

35. On March 15, 1983 DCPD private Minzak struck me several times and slammed my head against a police cruiser, arrested and incarcerated me under color of disorderly conduct.

36. On April 22, 1983 defendants Fish, Robbins and others published 36 CFR 50.19(e)(9)(10) in the Federal Register, and, in the opinion of USDC Judge William Bryant, violated 5 USC 552 by suspending the 30-day delay of effectiveness. The regulation was later withdrawn, but not before I was arrested under its color on April 27, 1983. Charges were dismissed.

37. On May 3, 1983 I heard Defendant Lindsey and Jerry Parr give false testimony under oath when they both asserted that an individual had used one of my signs to climb over the White House fence. Assertions of threats to presidential security, where none existed, were necessary in order to justify a judicial mandate to remove the signs from the White House sidewalk. But Judge William Bryant found that those allegations "fell apart at trial."

38. On May 5, 1983 I was arrested during the course of a demonstration to protest the May 3rd testimony of Lindsey and Parr. Charges were dismissed, and exculpatory evidence was de-stroyed by the Secret Service.

39. On June 17, 1983 various defendants again violated 5 USC 552 by suspending the delay of effectivenenss before imple-menting 36 CFR 50.19(e)(9)(10).

40. On July 1, 1983 private Walter Sherba repeatedly kicked, stepped on, and prodded me with his nightstick, for no reason.

41. During the trial in ERA v Clark, USDC CA 83-1243, various government officials gave false testimony and introduced photographs, taken during the winter of l98l, which they falsely presented as a portrayal of the situation existing during the winter of l982, as evidence to support their groundless claims of "substantial government interest."

42. On or about January 31, 1984 I was arrested with-out probable cause, charged with "camping". Charges were dismissed.

43. On or about June 6, 1984 my wife, Ellen Thomas, and myself were assaulted, had our literature, signs and NPS-permit-ted Mobile Speakers Platform destroyed, and were arrested without probable cause. I was acquitted at trial.

44. On or about June 23, 1984 I was arrested under color of "camping." Charges were dismissed.

45. On or about June 6, 1984 I witnessed U.S. Park Police officer David Haynes assault my associate Robert Dorrough, without probable cause. I photographed that event.

46. On or about June 6, 1984 I was assaulted by Officer David Haynes, without probable cause. During this assault I was pushed, and thrown with great force, into a structure, used by me for coummunications purposes, and under permit from the NPS. As a direct and proximate result of officer Haynes' actions, that structure was capsized, paint was spilt on the sidewalk, and I suffered physical injury. My wife photographed Officer Haynes' assault. The camera was seized by officer Haynes, and carelessly "lost." A year later, when it was finally returned, the film had been destroyed.

47. Some days later I arrived at the U.S, Park police property yard at 500 Brentwood Avenue, NE. At that time I discovered that many of the signs, which had been in perfect condition when I last saw them on June 6, 1984, had been de-stroyed beyond repair. Additionally I discovered that the NPS permitted structure, of exceptionally sturdy construction, had been totally demolished. I found these things in a dumpster along with a large quantity of the literature which had regularly been passed out in the course of my demonstration activities.

48. I was acquitted of those charges. However Officer Haynes falsely accused me of assaulting him, Park Police offic-ials published that defamatory lie throught the public media, and, although the Grand Jury refused to indict that charge, the false accusation remains on my record.

49. Officer Haynes again arrested Concepcion Picciotto, Ellen, my-self, and a few people who happened to be around us, on June 23, 1984. Those charges were dropped, but some of our signs were again destroyed.

50. On or about September 10, 1984, defendant Sandra Alley issued and distributed a memorandum arbitrarily proscribing var-ious of plaintiffs' expressive activities.

51. On October 10, 1984 Mr. Robbins and Mr. Lindsey super-vised the destruction of our reconstructed and NPS-permitted mobile communication speaker's platform. In addition, Mr. Lindsey unnecessarily (as I had specifically entrusted them to the care of a friend) ordered the removal of all my other signs and literature from Lafayette Park, and at least two of those signs were also destroyed.

52. On October 10, 1984 I was also arrested for "attachment to a tree" and "general injury to a tree." When the arresting officer, Braxton, took me to the sub-station I told him that I wanted to pay the fine on both charges.

53. Officer Braxton told me that I would be allowed to pay the fine after I had been booked.

54. I was taken to the holding cell. I saw J. C. Lindsey and Richard Robbins, both of whom had been on the scene of the arrest, enter another room, where they spoke with Officer Braxton.

55. A short time later officer Braxton came to the cell and told me that we were going to the Central Cell Block.

56. I asked: "What about me paying the fine."

57. "Too late for that," said officer Braxton. "You've got another charge. Resisting arrest."

58. "Did Lindsey and Robbins tell you to do that?" I asked.

59. "Yup," Braxton told me.

60. On October 15, 1984 private Murray, et al., seized and damaged three cloth banners in Lafayette Park. No charges were lodged.

61. On February 19, 20, and 21, 1985 USPP officers Duckworth and Bohn harassed and photographed me in the early morning hours.

62. On May 9, 1985 Park Police and NPS officials again seized our re-reconstructed NPS-permitted mobile speaker's plat-form, and arrested Ellen Thomas under color of disorderly con-duct when she protested that the structure was protected from confiscation by a year-old, active permit. That charge was dismissed.

63. On or about October 11, 1985, I was arrested without probable cause, for disorderly conduct. Those charges were dropped.

64. On June 8, 1985, a sign was confiscated from me. A citation was issued. Charges were dropped.

65. On August 20, 1985 various NPS and DOI officials acted in concert to publish 36 CFR 50.19(e)(11)(12) in the Federal Register.

66. On September 18, 1985 I hand delivered a petition for review of the proposed "sign size" regulation, pursuant to Execu-tive Order 12291 to Mr. Bedell, Acting Director of the Office of Management and Budget.

67. On or about November 10, 1986, in Lafayette Park, Lieu-tenant Hugh Irwin assaulted me and caused my false imprisonment without probable cause.

68. On or about March 20, 1987 Lt. Hugh Irwin directed the confiscation of various tools and materials with which I and several associates were preparing to erect a speaker's platform in accordance with a duly-authorizied permit from the National Park Service.

69. On or about May 9, 1988, at approximately 1425 hrs. U.S. Park Police Officer Sabate, #407, informed me that I had to give her my name.

70. When I asked what my alternative was Officer Sabate told me that I would be arrested, driven to and held at the sub-station until I revealed my name.

71. When asked why she needed my name, she said that she had to make out a report, using my name.

72. When asked why she had to make out a report she replied "because this is a demonstration and I have to make out a report on demonstrations."

73. When asked how long this policy on demonstrations had been in effect she said: "Ever since I've been here." She indicated that she was here since July, 1987.

74. Repeatedly, and in good faith, I have tried to reason with various Park Service officials so that I might effectively communicate my message, while complying with their regulations. Always I have been rebuffed in these efforts.

75. Despite these facts, and the additional fact that this professes to be a "nation of law" devoted to the principles of individual Freedom of Thought and Freedom of Expression, I have been arrested, by my reckoning, more than thirty (30) times since 1981 for performing symbolic acts with only the best of inten-tions.

76. Of those arrests only nine, by my reckoning, have resulted in conviction. To my knowledge in every instance where a criminal conviction has been the result of one of my symbolic acts, that conviction was accompanied by (a) an official misrep-resentation to the Court of a factual situation and/or less than a complete presentation of the complete factual situa-tion, or by virtue of (b) a regulation which was enacted pursuant to perjurious testimony by government officials.

William Thomas, Plaintiff Pro Se
l440 N Street NW, #4l0, DC 20005
(202) 462-0757