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.,          )
________________________________________)

ERRATA TO PLAINTIFFS' JUNE 9, 1989
CLARIFICATION OF COMPLAINT

INTRODUCTION

pg. 1 delete first para., substitute "Pursuant to their understanding of the Court's request at the hearing of January 9, l989, plaintiffs have cross-referenced the Appendix of Plaintiffs' Exhibits (hereinafter "Exhibit"), filed herewith, with the Complaint (hereinafter "C."), filed September 30, l988, and the Amended Complaint (hereinafter "AmC."), filed November 23, l988. Errors discovered during the cross-referencing process have also been corrected, as noted in the accompanying Errata."

pg.1 insert "(Exhibit B-2)" after "pilgrim" 7th line from bottom.

pg.1 insert "(Exhibit A-2)" after "land" 4th line from bottom.

pg. 2 substitute "B-6 and E-1" for "B" 3rd line from top.

pg. 3 delete "para. 44", substitute "para. 45", 7th line from top.

pg. 3 Substitute "Exhibit D" for "Ex &&" 4th line from bottom.

pg. 4 substitute "lll-B" for "&&", 7th line from top.

pg. 4 substitute "E-l, p. 2" for "&&" llth line from top.

pg. 4 substitute "E-3" for "E-3(a)" and "E-4" for "E-3(b)", l0th line from bottom.

pg.4 delete "Memorandum and Pre-trial," substitute "Orders" before "J. Oberdorfer" 9th line from bottom.

pg.4 insert "June 5, 1986 and June 3, l985" in place of "June 6, l985" 8th line from bottom.

pg. 4 substitute "l33-C," for "E-4" 3rd line from bottom.

pg. 5 substitute "l33-D," for "E-5"; substitute "November 2l" for "October 2l" lst line from top.

pg. 5 substitute "E-5" for "E-6" 7th line from top.

pg. 5 substitute "lll-C" for &&, l0th line from top.

pg. 5 substitute "lll-F" for &&, llth line from top.

pg. 5 substitute "lll-D" for &&, l3th line from top.

pg.5 add ", see also inter alia para. l24." to l4th line from top.

pg. 5 substitute "lll-E" for "&&" l3th line from bottom.

pg. 5 substitute "pilgrims'" for "pilgirms'" and "lll-G" for "&&", l0th line from bottom.

pg. 5 add "USDC CA 84-3552" 3rd line from bottom.

pg. 5 substitute "E-6" for "E-7", 2d line from bottom.

pg. 6 insert "filed" before "October", top line.

pg. 6 substitute "E-7" for "E-8" 2d line from top.

pg. 6 substitute "1984" for "l985" 8th line from bottom. Add "Inter alia para. 70." 8th line from top.

pg. 6 substitute "703 F.2d 589; Clark v. CCNV, S.Ct. Syllabus, p. l, June 29, l984" for "US App. No. CA 2445, p. ___; USDC App. No. CA 2445, p. ___."

pg. 6 insert "Inter alia, paras. 27-29" 3rd line from bottom.

p. 7 insert "Inter alia, para. 40.", 8th line from top.

p. 7 insert "Inter alia, para. 44" l2th line from top.

p. 7 insert "Inter alia, para. 49" 7th line from bottom.

p.8 substitute "Inter alia, para. 57" for "Exhibit 57" top line.

p. 8 insert "Inter alia paras. 65, 67." 5th line from top.

p. 8 insert "Inter alia para. 68." 9th line from top.

p. 8 insert "Inter alia para. 8l." l3th line from top.

p. 8 insert ~Exhibit 69, pp. l2, l3." l2th line from bottom.

p.8 substitute "to prohibit" for "of prohibiting" 9th line from bottom.

p. 8 substitute "ll30-A and ll3-B" for "___ and ___", bottom line.

p. 9 insert "Inter alia para. l3l." 5th line from top.

p.l0 substitute "l-A, -B, -C, -D, -E" for "(a),(b),(c),(d),(e)" l4th line from bottom.

p. l0 substitute "(Thomas)" for "He" l0th line from bottom.

p. l0 substitute "July 6, l98l" for "July 7, l98l."

p. l0 insert "p. l9" between "Exhibit 3" and "Recommendation" 6th line from bottom.

p.l0 insert "COMPARE Motion to Strike, Exhibit A." 3rd line from bottom.

p. ll insert "COMPARE Exhibit l.", 5th line from bottom.

p. l2 delete "EMPHASIS added" l5th line from bottom.

p. l2 substitute "43." for "l04?" l4th line from bottom.

p. l2 substitute "-A, -B, -C, -D, -E" for (a),(b), (c),(d),(e)," 9th line from bottom.

p.l2 substitute "December 6, 1983" for "December l3" 3rd line from bottom.

p. l2 insert "Inter alia paras. l3-22." 2d line from bottom.

p. l3 substitute "8-l2" for "9-l3" 8th line from top.

p. l3 insert "(COMPARE Exhibit 5)" l4th line from top.

p. l3 insert "See" before "Exhibit 3" l7th line from bottom.

p.l3 insert "; COMPARE Motion to Strike Exhibit 4, Attachment A." after "l9", l6th line from bottom.
p. l6 substitute "2l" for "30" 20th line from bottom.

p. l6 insert "COMPARE para. 8, 27, e.g." l2th line from bottom. p.l7 "see also Exhibit 24," delete "50.27(a)" 2d line from top.

p. l7 insert "Compare Exhibits 8 and 25" l6th line from top.

p.l7 insert "See also Exhibits 8, 9, 23, 25." 7th line from bottom.

p. l8 insert "Exhibit 32-A, November l3, l982, Officer Ferebee." bottom line.

p. l9 insert "Exhibit 36" before "p. 4)" 7th line from bottom.

p. 20 insert "-l2" after "4" 2lst line from top.

p. 20 substitute "4l" for "40" 9th line from bottom.

p.20 Substitute "December 6" for "December 13," 30th line from top.

p.2l insert "(inter alia para. 54)" after "etc.", l6th line from top.p. 2l insert "and require that they take place on the Ellipse."" after "activity" 8th line from bottom.

p. 22 substitute "March 9" for "March 8" 6th line from top.

p. 22 substitute "46-A" for "46" l6th line from bottom.

p. 22 substitute "46-B" for "47" l5th line from bottom.

p.22 insert "see also Exhibit l09, para. 2." llth line from bottom.

p.22 substitute "December 6" for December 13" 4th line from bottom.

p. 23 insert "test" before "imony" l8th line from top.

p. 23 substitute "May 19" for "May 16" 18th line from top.

p. 23 substitute "52" for "5l" 2lst line from top.

p. 23 delete "and their fabricated "interests" by other regulations," l2th line from bottom.

p.24 insert "COMPARE Amended Complaint, Thomas Declaration, p. l2." l0th line from top.

p.24 substitute "November 21" for "November 30" 11th line from bottom.

p. 25 delete "l8" bottom line.

p. 26 insert "COMPARE Exhibit 57." l4th line from bottom.

p.26 insert "(inter alia paras. 73, 74)" 6th line from bottom.

p.28 substitute "November 21" for "November 30" mid-page.

p. 28 insert "see also Exhibit C." after "at 63." mid-page.

p. 28 substitute "7l-A" for "7l" 8th line from bottom.

p. 28 insert "Exhibit 7l-B, photographs of the "crime."" 7th line from bottom.

p. 29 substitute "75-B" for "75", l0th line from bottom.

p. 29 insert "See also Exhibit 75-A, SS Report May 6, l983" 9th line from bottom.

p. 29 insert "and "alternative forums," Exhibit 76" instead of "Exhibit 75", 6th line from bottom.

p. 29 insert "Exhibit 3, p. l0" last line (ftn. 2/)

p. 30 substitute "inter alia para. l3l" for "supra. para. 76" lst line from top.

p. 30 substitute "64-A" for "65-A" llth line from bottom.

p. 3l substitute "79" for "80-A" l0th line from top.

p. 3l substitute "80-A" for "80-B" l2th line from top.

p. 3l substitute "80-B" for "80-C" l3th line from top.

p. 3l insert "COMPARE supra. para. 6l" l3th line from bottom.

p. 3l insert "COMPARE supra para. 39" 2d line from bottom.

p. 32 insert "Supra. para. 39" 3rd line from top.

p. 32 substitute "86" for "85" 5th line from top.

p. 32 delete "(parentheses added)." 5th line from top.

p. 32 insert "Exhibit 87", l5th line from top.

p. 32 delete "and under color of" 2d and lst lines from bottom.

p. 32 insert "p. l2" l0th line from top.

p. 34 substitute "l984" for "l983" l2th line from bottom.

p. 34 insert "On May 9, 1984" beginning of paragraph 94.

p.34 insert "(supra. para. 24)" after "(Exhibit 2)", para. 94.

p. 34 retrieve lost line, para. 94.

p. 35 substitute "l984" for "l094" llth line from bottom.

p. 35 insert "paras. 30-44" 3rd line from bottom.

p. 36 delete "and underlining" and justify 3rd line from bottom.

p. 37 insert "See Exhibit 64-B" l0th line from top.

p. 37 insert "paras. 36-39" 9th line from bottom.

p. 37 insert "paras. 36-39" last line on bottom.

p. 39 relocate 9th line from top.

p. 40 delete "Application, September 5, l984" and replace it with "September l8, l984" 8th line from top.

p. 40 add "and l20-B" 9th line from top.

p. 40 insert ", para. 85." l2th line from bottom.

p. 40 insert "see also Exhibit l20-B" 3rd line from bottom.

p. 4l substitute "l2l" for "l22" 9th line from top.

p. 4l substitute "l22" for "l23" l2th line from top.

p. 42 substitute "the White House" for "Reagan" 3rd line from top.

p. 42 substitute "l27-A" for "l27", llth line from top; add "see also Exhibit l27-B, Exhibit l27-C" l2th line from top.

p. 42 insert "COMPARE Exhibit ll3-B" l4th line from bottom.

p.43 delete "pp. 7556-7566", 2d line from top. Insert "Response to Federal Defendants' Motion to Dismiss, p. l4." and "COMPARE Exhibit ll3-B." 3rd line from top.

p. 43 insert "p. 2" after "l32" 6th line from top.

p. 43 insert "COMPARE Exhibit ll3-B" 7th line from top.

p. 43 delete "and" and "photographs; insert "l33-C, l33-D" l0th line from top.

p. 43 insert "pp. 26-29, 65-67, 94, 95" l2th line from top.

p. 43 insert "Plaintiffs do not file frivolous legal papers." l4th and l7th lines from top.

p. 43 insert "See Innuendos of Litigiousness, filed herewith" l6th and l9th lines from top.

p. 43 insert ""Theoretically"" 9th line from bottom.

p. 43 insert "p. 92" 7th line from bottom.

p. 43insert "l38. Plaintiffs are exercising their religious beliefs. Exhibits l38-A, -B, -C, -D, -E; see also Exhibit l32." between l37 and l39.

p.43 insert "l39. The government did not challenge the "authenticity" of NPS permits which would allow each activity for which plaintiffs had been convicted." 5th line from bottom.

p.43 insert "p. 45" after "Exhibit l39" 4th line from bottom.

p. 43 substitute "l40" for "l39" 2d line from bottom.

p. 43 insert " " outside "Plaintiffs...them." Substitute "l40, p. 8" for "l39" bottom line.

p.44 substitute "l4l. See Exhibit l4l" before "Declaration of Concepcion Picciotto" 3rd line from top.

p. 44 insert "l42. Lt. Irwin and other government agents forceably prevented plaintiffs from conducting a public gathering, which was planned in accord with NPS permit application March ll, l987." 5th line from top.

p. 44 insert "l43. Exhibit l43-A, A Question of Sanity; Exhibit l43-B, "are you crazy, or do you just prefer being cold?"" Last item on list.