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.,
                      Defendants.

PLAINTIFFS' (REDACTED) OPPOSITION TO THE FEDERAL DEFENDANTS' SUBMISSION OF JUDGE OBERDORFER'S ORDER OF SEPTEMBER 16, 1988, DEFENDANT MICHAEL CANFIELD'S SUBMISSION OF MAGISTRATE BURNETT'S MEMORANDUM OF DECEMBER 15, 1987
AND INNUENDOS OF LITIGIOUSNESS

INTRODUCTION

Pursuant to Federal Rule of Evidence 102, et. seq., plaintiffs hereby supplement the record of this case with documents of public record on file with the Clerk of this Court.

These documents are contained in the Appendix, filed this date, and are hereinafter designated as "Exhibit ."

BACKGROUND

THEORY OF MANIPULATION

At the hearing on December 5, 1988, Counsel for the federal defendants announced the intent to bring a Motion for Summary Judgment. Instead the government has opted to submit a voluminous Motion to Dismiss, supported by ten prodigous exhibits, not unlike the mythical titans.

It would appear that the AUSA, similar to a mythical Siren, would like to throw the Court into a frenzy by chanting a song:

"Thomas" (Memo p. 4), "Thomas," "Thomas," (id, id, p. 5), "Thomas,! "Thomas," "Thomas,! "Thomas," "Thomas," (id, id, id' id, id, p. 6), "Thomas," (id, p. 7), "Thomas," ''Thomas,!' (id, id, p 14), "Thomas, I' ['Thomas," (id, id, p. 16), ''Thomas,!' (id, p. 17), ''Thomas," ''Thomas," ''Thomas," (id, id, id, p. 23), "Thomas," "Thomas," "Thomas," "Thomas," (id, id, id, id, p. 27), ''Thomas,!' ''Thomas," "Thomas," (id,

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id, id, p. 28), "Thomas," "Thomas," (id, id, p. 29), "Thomas," (id, p. 30).

Next he monosyllabically recites the "Arrests of William Thomas," defendants' "Exhibit 4." See Motion to Strike, filed January 3, 1988.

Then comes the tale of monsters. Memo, p. 1.

Could it be that the U.S. Attorney is trying to hypnotize the Court into believing that Thomas is a monster? Compare, Exhibit B.

Plaintiffs turn here to address a more serious issue.

Why, one might ask, would the AUSA seek to convince the Court that Thomas is a monster? The answer seems apparent: so the Court will smash "Thomas and his cohorts" with no regret, compunction, or showing of specific "threat of harm to any person, property, or government interest."

It should not be forgotten that Thomas is not alone, and by crushing him others will suffer.

On December 5, 1988, plaintiffs filed, at the Court's request, a "Statement of Plaintiffs' Position on Spokesperson." We explained that each individual would preserve the right to speak on her/his own behalf regarding matters of personal perspectives on facts or principles.

Clearly this case is not only about Thomas.

This case is about Concepcion, Scott, Ellen, Philip, Mary, Sunrise, individuals, groups under twenty-five, the people of the United States (Complaint pares. 1-6), and democracy (Complaint pare. 81).

If this Court is distracted-by fables of Thomas setting fire to a crowded Aegean stable, the fact that defendants are burning Concepcion at the stake may go unnoticed.

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Why doesn't defendants' "Exhibit 4" elaborate on Concepcion?

She's been a "cohort" of Thomas since 1981. Memo, p. 4.

She's been arrested lots of times, often purportedly for "camping." SEE, e.g., Declaration of Concepcion Picciotto in Support of the Amended Complaint, pares. 13, 14, 15, 16, 17, etc.. What about the many arrests of Concepcion -- not to mention her other claims -- which have never received any judicial review?

Likewise, for one of innumerable possible examples, defendants' Motion to Dismiss offers absolutely no explanation as to the facts surrounding the arrest which led the U.S. Attorney to prosecute Philip Joseph with vexatious court proceedings until, with unexplained prosecutorial discretion, United States v. Joseph, USDC Cr. No. 88-235 was finally dismissed.

Surely the Court should not overlook the People of the United States. But defendants fail to say anything about David Sanchez, acquitted on September 15, 1988, of "camping" after a trial (USDC Cr. No. 88- ) before Judge Norma Holloway Johnson. Nonetheless, just a couple of weeks after his acquittal Mr. Sanchez was cited for purportedly "storing property" (US Park Police Citation No. 192602). That charge was dismissed by Magistrate Attridge on November 21, 1988, but no one has ever looked at the facts of the matter.

Consider also Casimer Urban Jr., Cr. No. 84-309, acquitted of "camping," J. Johnson; Robert Dorrough, Cr. No. 88- ___, acquitted of "camping," J. Oberdorfer; Robert Dorrough, Cr. No. 87-0122-M, CR 87-65, "unlawful structure" ("erecting a mass of snow"), dismissed.... -

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The list is much longer but these few examples illustrate a principle which Judge Oberdorfer has clearly articulated: "If your (government) suppresses the kind of protest that you are engaged in, we would be jeopardizing the liberty of all of us." Exhibit D, United States v. Thomas, USDC CR No. 83-186, Sentencing Transcript, p. 29, December 21, 1983.

Likewise, in their Motion to Dismiss, filed December 21, 1988, federal defendants' counsel leans heavily (e.g., Id, pgs. 1, 4, 5, 6, 7, etc.) on Thomas to bolster his argument that, for the sake of "judicial consistency .... th(is) Court should dismiss all constitutional, statutory and conspiracy claims against the federal defendants." Id, pg. 14.

Following the federal defendants' lead, the District of Columbia filed a Motion to Dismiss or for Summary Judgment supported by a Memorandum Opinion, Report and Recommendation of U.S. Magistrate Arthur Burnett (District of Columbia (D.C.) defendants' exhibit A) in Thomas, and an Order (D.C. defendants' exhibit C) entered in Thomas by Judge Oberdorfer.

At pages 5 - 7 of the federal defendants Motion to Dismiss Mr. Martinez relates his synopsis of Thomas.

Because it appears that defense counsel may be attempting to litigate this case on the basis of a skewered history of Thomas, plaintiffs submit 1) a different perspective of that history, 2) a brief response to footnotes 5 and 6 of federal defendants Memorandum in support of the Motion to Dismiss, 3) Magistrate Burnett's Memorandum Opinion Report & Recommendation on the Federal Defendants' Motion to Dismiss. Exhibit 3.

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HISTORY OF THE THOMAS CASES

"I am presently in the United States against my will. Having been brought here (Exhibits A-1, A-2) in violation of the laws of this country. Immediately, my own desire is to leave this country and to resume the activities in which I was engaged prior to the illegal interference of the authorities of this country. My personal experience has led me to conclude that the United States, in pursuit of its own pleasure and comfort, is actively engaged in the destruction of the planet on which I live and which I hold to be the property of my Creator. To work within the system that comprises the United States is, for me, to contribute to this destruction. In effect, I refuse the beastly mark without which one may (not) buy or sell. Because I cannot buy or sell, I am forced to live in the streets and subsist on what society throws away. So my very existence is a demonstration of the manner in which a truly moral person is compelled to live within an amoral society." USA v. Thomas, USDC Cr. No. 82-352, Sentencing Transcript, p. 20, July 5, 1983. COMPARE Exhibit 1-E.

"...I have waited patiently in the spirit of Diogenes and Ezekiel for the government of the United States to heed my grievance. While waiting I have employed my time by communicating to the general population my unpopular opinion that the differences between the United States and the Soviet Union are purely relative and, therefore, not adequate justification for plunging the world into a nuclear inferno. I have warned the American people that unless they alter their behavior, they will suffer the fate of Babylon in the 18th Chapter of Revelations. I have acted in the spirit of a warrior who runs many miles in the service of his people to deliver a message of bad tidings. He does not run to distress his people with his message, but rather, that the people might use his message for their own salvation. For his dedicated service, the warrior runs the risk of losing his head as the bearer of a truthful, but unflattering, message.
"...It would certainly seem a sorry commentary on the human legal system if the best of Courts can't accurately determine the difference between a sincere communicator of ideas and a 'camper."' Exhibit 37, USA v. Thomas, USDC Cr. No. 82-358, Trial Transcript, pp. 19-20, July 7, 1983.

Personally, Thomas has never had any desire to file civil actions. The only reason he started was in hopes of proving himself wrong.

"With the help of a lawyer, I don't think a citizen can accomplish this by himself, but .... a person like yourself could apply to this problem about structures and the problem about camping ... for getting quick administrative and quick

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judicial determinations ... as to whether the thing that the person wants to do is a violation o(f) the law, or not a violation of the law." Exhibit D, United States v. Thomas, USDC Cr. No. 83-186, sentencing transcript, page 21, December 21, 1983.

"(T)he courts in this courthouse are dedicated to facilitating your exercise of those rights. But they can't do it if your can't use the system that the courts make available. And if you have some conscientious objection to using that system, then the system has to deal with you on its own terms. Judge Oberdorfer, Id. at page 22.
"(P)eople like yourself with important messages -- and I do not demean your message -- can say it so that it can be heard in a way that messages have never before been hearable and seeable in the history of the world.
"You can stand in front of that White House, and your message can be seen all over the globe within hours, and your right to do that is guaranteed.
"The idea was to have these problems resolved in that sort of civilized way, instead of having police swoop down on people and put them in paddywagons and take them to the station and then have them tried in a criminal way, where they are fingerprinted and mugged, and, if they are guilty, go to jail." Id. page 26.
"I am sensitive, perhaps more sensitive than most, to the fact that if your country suppresses the kind of protest that you are engaged in, we would be jeopardizing the liberty of all of us." Id. page 29.

Although Thomas believed strongly in the principles of Jus-tice, and even felt that court rules, if rationally applied, could be useful to develop evidence to the end that truth may be ascertained and proceedings justly determined, frankly, his befief that the courts are merely a corrupt gear in a corrupt machine was what Thomas saw as a "conscientious objection to
using that system."

Judge Oberdorfer seemed so sincere. Thomas, who clings stubbornly to the premise that people are basically good, decided to follow Judge Oberdorfer's advice, hoping to find that his "conscientious objection" was in error and that the "system" actually was "civilized". Thereupon the following transpired:

A) Complaint 84-3552 filed! November 21, 1984.

B) Memorandum and Order filed, June 3 1985, J. Oberdorfer:

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"Plaintiff brings this action to enjoin the defendants from interfering with the 'reproachful vigil' that he maintains in the vicinity of the White House and Lafayette Park.... The federal defendants correctly point out that the plaintiff can no longer challenge the Department of Interior regulations under which he and his fellow protectors have been arrested... (Cites omitted.)
"Nevertheless, many of the issues raised in plaintiff's voluminous pro se complaint cannot be resolved by the pending motions.... These claims have been summarized in a
'Clarification of Complaint' filed by the plaintiff at the Court's request.
........... Exhibit E-4.
"Plaintiff's complaint states a substantial federal claim. The fact that the constitutionality of the DOI regulations is well-settled does not prevent the plaintiff from claiming, pursuant to 42 U.S.C. Section 1983 and Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) (footnote omitted), that defendants have violated his constitutional rights in the course of enforcing the regulations and the law of the District of Columbia." Id.

C) Amended Complaint filed October 19, 1985.

D) Memorandum and Pretrial Order filed June 5, 1986, LFO:

"This action is now before the Court on plaintiff's Amended Complaint (filed Oct. 19, 1985).... By Order of April 9, 1986, plaintiff was required to complete a Statement of claim regarding each named defendant. Plaintiff affirms that his case 'is about a conspiracy to deprive [him] of [his] civil rights, in violation of federal law.' Statement of Claim (filed April 22, 1986 quoting Memorandum to the Court at 1 (filed april 2, 1986)). Plaintiff lists each defendant and each act allegedly undertaken by that defendant in furtherance of the alleged conspiracy. This detail provides defendants with the definite statement required by Fed. R. Civ. P. 8.... (Exhibit E-4, parentheses in original)
"Plaintiff's Statement of Claim, as well as the allegations previously found to be potentially meritorious, indicate that plaintiff's claim involves two discrete issues.
"1) Whether any of the named defendants conspired to deprive plaintiff of his civil rights, in violation of federal law; and
"2) Whether any of the defendants individually committed any unconstitutional acts toward plaintiff, specifically whether any defendants 'committed unconstitutional excesses in their efforts to arrest plaintiff pursuant to local stateutes and DOI regulations.' Memorandum and Order at 2 (filed June 3, 1985).... (parentheses in original)
"Because plaintiff's claims involve numerous defendants and he is proceeding pro se, it is important that discovery be closely supervised. This action will be referred to United States Magistrate Arthur Burnett for supervision of discovery and pretrial proceedings.... Depositions should

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also be taken under the Magistrate's supervision. (Id, pgs. 1 thru 3)

"ORDERED: that the trial shall commence at 9:30 A.M. on October 20, 1986...
"ORDERED: that each of the parties shall file, on or before September 12, 1986,
a trial brief...." Id, pg. 4.

E) Plaintiffs' trial brief was filed on September 22, 1986, (Defendants never filed a trial brief.)

F) ORDER filed September 26, 1986, J. Oberdorfer, referring pending motion for summary judgment to Magistrate Burnett for hearing and recommendation.

G) ORDER filed November 8, 1986, Mag. Burnett, resetting trial to December 15, 1986.

H) 12/8/86 trial reset for 1/26/88, J. Oberdorfer.

I) Magistrate Burnett's Memorandum Opinion, Report & Recom-mendation, filed January 13, 1987, see, Exhibit 3:

"Before the undersigned U.S. Magistrate upon reference from the Court (Oberdorfer, J.), is the motion of federal defendants (footnote omitted) for summary judgment pursuant to Rule 56(b), Fed. R. Civ. P., with respect to plaintiff's common law tort claims of assault and battery, false imprisonment and unlawful arrest, 42 U.S.C. Sections 1983 and 1985 civil rights claims, and claims under the First, Fourth, Fifth, Sixth and Ninth Amendments, alleged by plaintiff, Mr. William Thomas." Id, pg. 1.
"(P)laintiff's principal contention is that these supervisory officials conspired among themselves, and with other federal agents and officers, in an effort to have him unlawfully arrested, harassed and intimidated in order to discourage plaintiff from continuing the free exercise of his First Amendment rights...." Id, pg. 4.
"The Magistrate heard argument of counsel on these and other allegations at a hearing held on November 14, 1986 at which plaintiff appeared pro se.... The Magistrate has since then again reviewed ... the testimony taken upon deposition in the presence of the Magistrate of ten (10) [government] witnesses in the case, as well as relevant portions of the court record. After consideration of these matters ... the Magistrate concludes that the motion of the federal defendants must be denied. [Brackets added.]
"... (T)he burden is on the federal defendants to show that there are no genuine issues of material fact ... Adickes v. S.H. Kress, Co., 398 U.S. 144 (1970).... Here, material facts are in dispute involving whether supervisory officials and officers acted in bad faith, either in a conspiracy or by

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combined action, to deprive plaintiff of his First Amendment rights which precludes granting summary judgment for the defendants. Id, pgs. 5 & 6.

"(T)here remains an incredible number of incidents stemming from (plaintiffs') arrests on which reasonable minds might well differ as to the arresting officers' subjective intent and whether their actions involved police misconduct." Id, pgs. 8 & 9. (Parentheses substituting.)
"Having carefully and thoroughly reviewed plaintiff's pleadings, the Magistrate concludes that there exist sufficient troublesome incidents raising genuine issues of material facts in dispute in this case, which mandate proceeding to trial on plaintiff's causes of action for both injunctive and declaratory relief." Id, pg. 14.

J) January 16, 1987, Pretrial conference set for 1/20/87.

K) January 20, 1987, further status set for 2/5/87.

L) February S. 1987, schedule for motions set.

M) ORDER (filed 4/16/87) setting status conference on May 1, 1987.

N) April 30, 1987, telephone call from J. Oberdorfer's clerk to inform that status conference set for 5/1/87 was "indefinitely" postponed. No further hearing has been held. Exhibit E-2.

O) Due to the sluggish nature in which 84-3552 was proceeding, as well as the fact that plaintiffs were subject to continuing police misconduct, Complaint 87-1820 was filed on July 6, 1987 to give the judiciary another chance to correct the situation.

P) ORDER filed November 30, 1987, Oberdorfer J., denying plaintiffs' Motion to Consolidate 84-3552 and 87-1820.

Q) Memorandum and Order filed February 16, 1988, dismissing the complaint against the Washington Times defendants in 87-1820 and CONSOLIDATING the remaining claims with those in 84-3552.

R) Order filed September 16, 1988, dismissing the remaining claims.

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SYLLOGISTIC REDUCTION

Dolefully we reduce Thomas to this syllogism:

PLAINTIFFS:

BEGIN from 1) the premise that: "The Law

Promotes Civilization," 2) apply as standards the First, Fourth, Fifth, Sixth, Ninth, Fourteenth Amendments of the Constitution of the United States; and 3) file a Complaint claiming that they have been the target of "police state tactics" (Original Complaint filed November 21, 1984, pg. 111, pare. 145), in the form of "numerous common law torts," by which a "mindless bureaucracy" (Id.) allegedly intended, to stifle plaintiffs' "socially beneficial, continuous presence in a public park," and thereby "the liberty of us all";

PROCEED through a judicial system which 1) repeatedly (e.g. June 3, 1985, June 5, 1986, validated the legal basis of the Complaint, and that there are "factual issues in dispute" (e.g. January 13, 1987); 2) refused to conduct a trial, or even comment on the disputed facts; 3) directed the PLAINTIFFS to obtain a "permit" (which would do nothing to alleviate the false arrests, false imprisonments, assaults, destruction of property, lies, and the other assorted totalitarian police excesses that had initially prompted plaintiffs to seek the Court's protection); while 4) instructing DEFENDANTS in how to fabricate their "permit" so as to eliminate plaintiffs' "socially beneficial, continuous presence in a public park," and, thereby, "the liberty of us all." As the record seemingly contains no evidence that the Court has NOT condoned injustice, turned a blind eye to "secret police tactics," and coddled a "mindless bureaucracy," plaintiffs can only;

CONCLUDE that: "The Court Promotes Chaos."

May the Lord help us to discover whether this conclusion is valid, and if so, to correct it.

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Re FEDERAL DEFENDANTS' FOOTNOTES 5 & 6

PLAINTIFF: " ... I have made a number of concessions such as filing this lawsuit which has consumed thousands of hours of my time, and taken me out of Lafayette Park where I should be ..."
THE COURT: "You are talking about the civil case you filed?"
PLAINTIFF: "Civil Action 84-3552."
THE COURT: "I am not concerned with that case. It has nothing to do with this case." Exhibit 134, p. 244, see also p. 226; see also Exhibit 137, p. 81.

Because Mr. Martinez has brought to the Court'" attention certain facts -- which make no claims, are unsupported by law, but present ideas which might be misunderstood -- plaintiffs think it prudent to put those facts into context.

Footnote 5, at page 5 of Memorandum in Support of the Federal Defendants' Motion to Dismiss, relates to notices of appeal which were filed "from Judge Oberdorfer's decisions." All this fact illustrates is that Thomas, Ellen Thomas, and Concepcion Picciotto each fulfilled the demands of two individuals, employed by the Clerk's Office of this Court, who advised the appeal "would not be noted" unless more notices were entered.

Subsequently all the following notices of appeal were filed, each at the direction of a clerk. The initial notices of appeal, 88-5367, and 88-5368, which were rejected by the clerks, would have sufficed.

Thomas v. U.S. Attorney (footnote 6), 1/ litigated by Mr. Martinez, did not specifically "relate to (Thomas) activities in Lafayette Park." Actually, it grew out of the seizure of Thomas'

1/ Defendant's footnote six does not mention that plaintiffs have had some limited success in criminal litigation. Exhibit 135

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papers, purportedly at the direction of the U.S. Attorney, while Thomas was imprisoned.

Picciotto v. Hodel (id), challenged the unprecedented closure of parts of Lafayette Park during the first state visit of Mikhael Gorbachev, in December, 1987. Mr. Martinez represented that the closure of the park was a one-shot deal that wouldn't be repeated, and that suit was ultimately dismissed as "moot." 2/

But it was not entirely unsuccessful; plaintiffs' signs remained during Mr. Gorbachev's visit, and Judge Oberdorfer called it a "good exercise." Exhibit 136, p. 5.

re Return of Property to Concepcion Picciotto (id), was a sorry case. As can best be recalled the "property" involved consisted of about 2,500 pieces of literature, a pair of gloves, a pair of scissors, and a handbag-sized camera case containing artist's brushes and oil paints, which had been forcibly seized from Concepcion's immediate possession as "stored property," and the government did succeed in keeping all that stuff.

Saffron and Picciotto v. Clark, was filed by the ACLU.

"The test of legal frivolity is whether (one) can make rational argument on law and facts in support of his claims." Wiggins v. New Mexico State supreme Court Clerk, 664 F.2d 831.

Perhaps Wiggins explains why footnotes 5 & 6 make no claims.

MONSTROUS OR MERELY HOMELY?

On June 3, 1981, plaintiff William Thomas was a "penniless

2/ Time has proven that officious closings of Lafayette Park wasn't a one shot deal. For example, parts of the park were closed in September, 1988 on the unprecedented occasion of a party at the Blair House. As the Libyans say: once the camel gets his nose into the tent there's no stopping him.

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wanderer and a pilgrim" (Complaint, exhibit 1), who, acting upon a sincere religious conviction that the Creator of the Universe had instructed him to devote his life to public discourse on issues of broad public concern (i.e., "destroying the earth and exploiting its inhabitants ... the principles of the Declaration of Independence ... the service of Truth, Justice and Freedom," id.), initiated a symbolic continuous presence to promote "gathering at the White House to pray for Reason, Sanity, and an End to War, in illustration of the ideals of non-violence." Id.

An article which appeared in the Boston Globe during August, 1981 (Exhibit B-7 and Exhibit 6) accurately stated:

"Thomas says there's only one reason he bothers to talk to other people; to provoke them into thinking about the existence of God, 'because if they believe there is no justice beyond what we can see in one lifetime, then the rule of the earth will continue to be Might is Right - and it isn't'."

Notwithstanding the facial grandiosity of instructions from the Creator of the Universe (see Thomas' Declaration in Support of the Complaint, pare. l), evidence will show that Thomas is not fanatical, as indicated by the Boston Globe:

"'I can clearly see that there are many different concepts of reality, but a concept of reality dosen't change the actual reality ... There is a real plane and an imaginary plane, and when we live in the imaginary plane, it causes chaos' - and that, he says, is why the world is in the mess it is in festering with war, crime, and assorted petty personal problems." See also Exhibit 138, USA v. Thomas, DCDC Cr. No. 87-61, Sentencing Tr., 1-28-1988, pg. 7.

In fact Thomas declares that "the practical aim of (his) continuous reproachful presence has been to be available on a 24hour-a-day basis in order to communicate (his) ideas, opinions, suggestions and theories, free of charge to any who ask, hoping

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to identify the problems which plague human society and, if only by identifying the problems, help in some degree to solve them." Declaration of William Thomas in Support of the Complaint, pare. 7; see generally, pares. 1 - 8. See also Exhibit D, USA v. Thomas, CR No. 83-186, sentencing trans. p. 24.

Over the years the other named plaintiffs have adopted, for practical reasons (see, Complaint pares. 5 and 21), methods of approaching reality similar to that practiced by Thomas.

There is convincing evidence to show that the government was aware of these facts, but actively engaged in or abetted a propaganda campaign - including, among other media, organs of the public press, the Federal Register, and official government documents - intended to demean plaintiffs and distract attention from the plaintiffs' issues.

Respectfully submitted,

//s// w thomas
William Thomas, Pro se
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757

CERTIFICATE OF SERVICE

I William Thomas, hereby state that, on this 17th day of January, 1989, I hand delivered a copy of the foregoing plaintiffs' Response to the Federal Defendants' Submission of Judge Oberdorfer's Order of September 16, 1988, and Innuendos of Litigiousness, and to Defendant Michael Canfield's Submission of Magistrate Burnett's Memorandum of December 15, 1987 to the offices of Assistant U.S. Attorney Michael Martinez, Judiciary Square, 555 4th Street, N.W., Washington, D.C., and Arthur Burger, 1350 Pennsylvania Avenue, N.W., Washington, D.C..

//s// w. thomas
William Thomas