MARY HUDDLE, et al., Plaintiffs, v. Civil Action No. 88-3130 JHG RONALD WILSON REAGAN, et al., Defendants.
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,
P.O. Box 27217
Washington, D.C. 20038