UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE and PHILIP JOSEPH, et. al.,
                Plaintiffs, Pro Se

         versus                       CA 88-3130-JHG
                                      Judge Joyce Hens Green
RONALD WILSON REAGAN, et. al.,

FEDERAL DEFENDANTS' OPPOSITION TO PLAINTIFFS'
MOTION TO STRIKE FEDERAL DEFENDANTS' EXHIBIT 4

Plaintiffs have moved to strike federal defendants' Exhibit 4 for a variety of reasons, the most prevalent of which is that it does not comply with various federal rules of evidence. Plaintiffs' motion should be denied. Exhibit 4 was not offered to the Court as evidence but rather as a hopefully helpful summary of William Thomas' many arrests and convictions for violating the regulations he takes issue with in this case. Indeed, the compilation is an updated and corrected version of a similar compilation undertaken by former Magistrate Burnett in 1986 in Thomas v. United States, C.A. No. 84-3552. That summary was attached as an exhibit to one of Magistrate Burnett's recommendations to Judge Oberdorfer, and is part of the public record in that case.

In any case, plaintiffs' motion proves the very point that the federal defendants were attempting to illustrate: that each of the plaintiffs, but particularly William Thomas, have been arrested and convicted numerous times for a variety of offenses proscribed by 36 C.F.R. 7.96. In view of the foregoing, the federal defendants urge the Court reject plaintiffs' motion by
signing the attached proposed Order.

Respectfully submitted,

/s/Jay B. Stephens
JAY B. STEPHENS, DC BAR #177840
United States Attorney

/s/John D. Bates
JOHN D. BATES, DC AR #934927
Assistant United States
Attorney

MICHAEL L. MARTINEZ, DC BAR #347310
Assistant United States Attorney

2

CERTIFICATE OF SERVICE

I hereby certify that this 6th day of January, 1989, I had one copy of the foregoing Opposition Memorandum hand delivered to William Thomas, addressed as follows:

William Thomas
1440 N Street, N.W.
#410
Washington, D.C. 20005

A copy was also mailed via first class U.S. mail to:

Arthur Burger, Esquire
Assistant Corporation Counsel
Third Floor, District Building
1350 Pennsylvania Avenue, N.W.
Washington, D.C. 20004

MICHAEL L. MARTINEZ, DC BAR #347310
Assistant United States Attorney
Room 4126 Judiciary Center 555
Fourth Street, N.W.
Washington, D.C. 20001
(202) 272-9195