UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLOMBIA

MARY HUDDLE, et al.,

Plaintiffs,

v.                               Civil Action No. 88-3130 JHG

RONALD WILSON REAGAN,
  et al.,

Defendants.

DECLARATION OF SCOTT GALINDEZ IN SUPPORT OF PLAINTIFFS' RESPONSE TO THE THE FEDERAL DEFENDANTS' OPPOSITION TO PLAINTIFFS' MOTION FOR SANCTIONS OR OTHER DISCIPLINARY ACTION

I, Scott Galindez, hereby declare under penalty of perjury that the following statement is true:

1. During the first week of February, 1989 I read a copy of the federal defendants' Reply to Plaintiffs' Opposition to the Motion to Dismiss and to all of the Plaintiffs' Other Submis- sions, filed on January 27, 1989.

2. During my initial reading of the matter, footnote 3 immediately caught my attention. I could not believe that Mr. Martinez could possibly claim that religion was a new-found claim by the plaintiffs.

3. First of all, I have read prior transcripts and complaints filed by William Thomas and have seen numerous religious claims. For that reason alone I was shocked to think such a blatant inaccuracy would be filed by the U.S. Attorney's Office.

4. Secondly, I was also disappointed that Mr. Martinez seems to be ignoring the other plaintiffs in this case. I arrived in December of 1986, and from that time forward, the individuals (plaintiffs) in this case have been discussing and following sincerely-held religious beliefs.

5. Mr. Martinez is correct that a few of the plaintiffs first made religious claims in April of 1987. For Philip Joseph, Steven Semple and myself the reason is simple; this was the first time we ever had any reason to make the claim. But from what I know and from what I have read it seems that for Mr. Martinez to make this claim about William Thomas, Ellen Thomas, and Concepcion Picciotto is an incredible misrepresentation.

6. Footnote 3 raised my ire as soon as I saw it. So Mr. Martinez's claim that Mr. Thomas in particular has reacted to this claim seems another mistaken opinion.

Under penalty of perjury,

Scott Galindez
P.O. Box 27217
Washington, D.C. 20038