MARY HUDDLE and PHILIP JOSEPH, et. al., ) ) AND ) ) CONCEPCION PICCIOTTO, pro se ) P.O. Box 4951 ) CA 88-3130-JHG Washington, DC 20008, ) Judge Joyce Hens Green plaintiffs, ) ) versus ) ) RONALD WILSON REAGAN, et. al., ) defendants ) ________________________________________)
Pursuant to rule 65, plaintiff hereby moves for the issuance of a temporary restraining order to restrain and enjoin the defendants from preventing or interfering with plaintiffs' communication to any representives of public media organs, or members of the general public.
In support of this Application plaintiffs submit a Certification, pursuant to Local Rule 205 (a), and Declarations by Concepcion Picciotto and Joseph Vigorito concerning the specific facts which gave rise to this Application for a Temporary Restraining Order.
U.S. Park Police Officer Berkowitz, whose actions prompted this application, appears frequently in the papers previously filed in this case. See, e.g., Amended Complaint, paras. 23, 24, 25 and 26. Declaration of Concepcion Picciotto in Support of the Amended Complaint, para. 20. Declaration of William Thomas in Support of the Amended Complaint, paras. 29, 41, 43.
WHEREFORE, plaintiffs pray this court will temporarily restrain:
(1) the defendants, their agents, and all persons acting under their direction and authority from disrupting or interfering with plaintiffs' communication to the general public and/or members of the communications media;
(2) the Park Police from assigning Officer Berkowitz to duty in Lafayette Park.
P.O. Box 3942
Washington, D.C. 20008
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
I William Thomas, hereby state that, on this 10th day of September, 1989 I caused a copy of the foregoing Plaintiffs' Application for a Temporary Restraining Order to be hand-delivered to the Office of U.S. Attorney at Judiciary Square, 555 4th Street N.W., Washington, D.C.