Thomas
Peace Park Anti-nuclear Vigil
P.O. Box 27217
Washington, D.C. 20038
September 26, 1989
Dear Mr. Martinez:
We would appreciate it if you would make available to
us the following materials as discovery in Huddle v. Reagan, USDC
88-3130.
1) all intra-departmental and inter-agency documents which
have been generated since June 3, 1981 within the possession,
custody or control of the Secret Service, Department of Interior,
National Park Service, U.S. Park Police, the White House, White
House Counsel, Office of Management and Budget, and the District
of Columbia Metropolitan Police, which relate to the presence
and /or activities of any or all plaintiffs and/or the White House
Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil,
2) all intra-departmental and inter-agency documents which
have been generated since June 3, 1981 within the possession,
custody or control of the Secret Service, Department of Interior,
National Park Service, U.S. Park Police, the White House, White
House Counsel, Office of Management and Budget, and the District
of Columbia Metropolitan Police, which relate to the enactment
of any statutes or regulations (including, but not limited to
36 CFR Sections 7.96 (i)(1), 7.96 (g)(5)(viii)(A)(2), 7.96 (g)(5)(ix)(A)(2),
7.96 (g)(5)(x)(A)(3), 7.96 (g)(5)(x)(A)(4), 7.96 (g)(5)(x)(B)(2),
7.96 (g)(5)(xii), 7.96 (g)(5)(xiii), including, as applicable
to each regulation, as it was formerly codified under 36 CFR Sections
50.27 36 CFR 50.19(e)(9)(10), and 36 CFR 50.19(e)(11)(12), which
have had, or which will have, the effect of or removing, curtailing,
or diminishing the presence and/or activities of any or all plaintiffs
and/or the White House Anti-nuclear Vigil and/or the Peace Park
Anti-nuclear Vigil, in Lafayette Park or the White House sidewalk,
3) all incident and arrest reports which have been generated
since July, 1986 within the possession, custody or control of
the Secret Service, Department of Interior, National Park Service,
U.S. Park Police, the White House, White House Counsel, Office
of Management and Budget, and the District of Columbia Metropolitan
Police, relating to any or all plaintiffs and/or the White House
Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil,
or their activities in Lafayette Park or the White House sidewalk,
4) all photographs, video and audio tapes which have
been generated since July, 1986 within the posses-sion, custody
or control of the Secret Service, Department of Interior, National
Park Service, U.S. Park Police, the White House, White House Counsel,
Office of Management and Budget, and the District of Columbia
Metropolitan Police, relating to any or all plaintiffs and/or
the White House Anti-nuclear Vigil and/or the Peace Park Anti-nuclear
Vigil, or their activities in Lafayette Park or the White House
sidewalk, and specifically:
a) All Uinted States Park Police memoranda, regulations, or directives respecting the enforcement of 36 CFR Sections 7.96
(I)(1), 36 CFR 7.96(e)(9)(10), and 36 CFR 7.96(e)(11)(12), including,
as applicable to each regulation, as it was formerly codified
under 36 CFR Sections 50.27 and 50.19,
b) the name of any Park Police Officer involved in any
arrest under the "camping" regulation,
c) the substance of oral instructions, if any, given to
any Park Police Officer who was involved in any arrest under the
"camping" regulation,
d) the names of all persons observed by U.S. Park Police
officers to be sleeping in Lafayette Park, and in any other park
within the "Memorial Core" area since July, 1986,
e) the names of all persons arrested for allegedly violating
the "camping" regulation since September 25, 1984, the
dates of those arrests, and the disposition of the charges in
each case,
f) any and all notes of observations, including case
incident reports, criminal reports, or any other writings concerning
any or all plaintiffs and/or the White House Anti-nuclear Vigil
and/or the Peace Park Anti-nuclear Vigil, or their activities
in Lafayette Park or the White House sidewalk generated by officers
of the United States Park Police, Officers of the United States
Secret Service, Officers of the Metropolitan Police, or by any
other official of the United States government or of the government
of the District of Columbia since July 1986.
5) plaintiffs ask for leave of Court to supplement these
requests as plaintiffs' investigation may reveal further evidence
of wrongful conduct, particularly of motivation contrary to the
intent and provisions of 5 U.S.C. 552 on the part of the Secret
Service, the Park Police, the District of Columbia Metropolitan
Police, Department of Interior, National Park Service, White House,
White House Counsel, Office of Management and Budget, or other
members of the executive branch whose influence impacts on the
promulgation and enforcement of regulations relating to the activities
of any or all plaintiffs and/or the White House Anti-nuclear Vigil
and/or the Peace Park Anti-nuclear Vigil, or their activities
in Lafayette Park or the White House sidewalk.
Sincerely,
William Thomas