UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MARY HUDDLE and PHILIP JOSEPH, et. al.,) ) Plaintiffs, Pro Se ) ) CA 88-3130-JHG versus ) ) Judge Joyce Hens Green RONALD WILSON REAGAN, et. al., ) ________________________________________)
On November 18, 1988 the U.S. Attorney filed a Notice which contended that "this civil action appears to be related to two other consolidated actions recently dismissed by Judge Oberdorfer." Plaintiffs respectfully oppose that contention.
While it is not inaccurate to say that during the four years that Judge Oberdorfer entertained the Thomas cases some of the issues in those cases might have been related to some of the issues in the instant matter, however, it is entirely inaccurate to say that any of those issues were "resolved" (Notice, pg. 1) by Judge Oberdorfer.
In fact, Judge Oberdorfer's Order of September 16, 1988 simply states that Thomas v. U.S.A, CA. No. 84-3552 was dismissed "without prejudice."
More importantly, the instant case raises entirely novel issues. 1/
The U.S. Attorney observes that an appeal was noted in those cases on November 9, 1988. As indicated in Plaintiffs' Motion
1/ Apart from any similarity of issues, some of the inci-dents alleged in this case, and which merit immediate atten-tion (see, Plaintiffs Motion for Preliminary Injunction and Tem-porary Restraining Order, filed November 23, 1988), had not yet occurred when the Thomas Order was filed on September 16th.
for Reconsideration of Judge Oberdorfer's September 16, 1988 Order, the issue on appeal will merely be the sufficiency of a dismissal in the face of "an incredible number" of "genuine issues of mater-ial facts in dispute." Id., Memo pgs. 5 and 6, para. I.
Moreover, assuming that the relationship suggested by the U.S. Attor-ney actually did exist, plaintiffs here would certainly be vulnerable to dispositive motions under the doctrines of res judicata or col-lateral estoppel.
In summary, under the circumstances existing in the wake of Judge Oberdorfer's dismissal -- without prejudice -- no proce-dural relation can presently be said to exist between this case and any other of which plaintiffs are aware.
Respectfully submitted,
________________________
Scott Galindez
Plaintiff, Pro Se
P.O. Box 27217
Washington, D.C. 20038
____________________________
Concepcion Picciotto,
Plaintiff, Pro Se
Post Office Box 4931
Washington, D.C. 20008
_____________________________
Philip Joseph, Pro Se
P.O. Box 27217
Washington, D.C. 20038
_____________________________
William Thomas, Pro Se
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757
_____________________________
Ellen Thomas, Pro Se
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757
MARY HUDDLE and PHILIP JOSEPH, et. al., ) ) Plaintiffs, Pro Se ) ) CA 88-3130-JHG versus ) ) Judge Joyce Hens Green RONALD WILSON REAGAN, et. al., ) ________________________________________)
I William Thomas, hereby certify that, on this ____ day of November I caused a copy of the foregoing Plaintiffs' Opposition to the Notice of Related Cases Filed by the United States Attorney on November 18, 1988 to be served by first class U.S. mail, postage prepaid, upon the office of Michael Martinez at 555 4th Street N.W., Washington, D.C.
____________________________________
William Thomas
WILLIAM THOMAS, et. al., ) ) Plaintiffs, Pro Se ) ) CA No. 84-3552-LFO versus ) ) CA No. 87-1820-LFO THE UNITED STATES, et. al., ) ___________________________________)
Please take notice that this 23rd day of November, 1988, plaintiffs filed the attached Challenge to the Notice of Related Cases in Huddle v. Reagan, Civil Action No. 88-3130.
Respectfully submitted,
____________________________
Concepcion Picciotto,
Plaintiff, Pro Se
Post Office Box 4931
Washington, D.C. 20008
_____________________________
William Thomas, Pro Se
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757
_____________________________
Ellen Thomas, Pro Se
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757
I William Thomas, hereby certify that, on this ____ day of November I caused a copy of the foregoing Notice of Filing Plaintiffs' Opposition to the Notice of Related Cases Filed by the United States Attorney on November 18, 1988 to be served by first class U.S. mail, postage prepaid, upon the office of Michael Martinez at 555 4th Street N.W., Washington, D.C.
____________________________________
William Thomas