MARY HUDDLE and PHILIP JOSEPH, et. al., )
                   plaintiffs,          )
                                        )
          versus                        )         CA 88-3130-JHG
                                        )     Judge Joyce Hens
RONALD WILSON REAGAN, et. al.,          )
                   defendants           )
________________________________________)

Plaintiffs hereby move the Court to compel discovery of documents and photographs in the possession of the defendants, or agencies, officers, or employees of the United States government which are directly related to the allegations of this Complaint. In support of this motion plaintiffs submit herewith a Declaration of William Thomas.

WHEREFORE, plaintiffs pray this court will compel defendants to provide plaintiffs with:

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, regul-ations, 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.

Respectfully submitted,

_____________________________
Sunrise S. Harmony
P.O. Box 27217
Washington, D.C. 20038

_____________________________
Ellen Thomas
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757

_____________________________
William Thomas
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757

_____________________________
Concepcion Picciotto
P.O. Box 4931
Washington, D.C. 20008

I William Thomas, hereby state that, on this 18th day of October, 1989 I caused true copies of Plaintiffs' Motion To compel Discovery and a Declaration of William Thomas in Support of the Motion to be hand-delivered to the offices of Assistant U.S. Attorney Michael Martinez at Judiciary Square, 555 4th Street N.W., Washington, D.C. 20001, and Arthur Burger, Assistant Corporation Counsel, third floor, District Building, 1350 Pennsylvania Avenue, Washington, D.C. 20004.

_____________________________
William Thomas

MARY HUDDLE and PHILIP JOSEPH, et. al., )
                   plaintiffs,          )
                                        )
          versus                        )         CA 88-3130-JHG
                                        )     Judge Joyce Hens
RONALD WILSON REAGAN, et. al.,          )
                   defendants           )
________________________________________)

I, William Thomas, hereby declare under penalty of perjury that on September 26, 1989 I hand-delivered a printed list to the office of Assistant U.S. Attroney Michael Martinez requesting that plaintiffs be provided copies of the various documents, photographs and records which plaintiffs describe in the accompanying Motion.

On or about October 13, 1989 I received a letter from Assistant U.S. Attorney John D. Bates which refused to supply the requested documents.

Wherefore, pursuant to the provisions

Under penalty of perjury this ___ day of September, 1989.

_____________________________
William Thomas
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757

MARY HUDDLE and PHILIP JOSEPH, et. al., )
                   plaintiffs,          )
                                        )
          versus                        )         CA 88-3130-JHG
                                        )     Judge Joyce Hens
RONALD WILSON REAGAN, et. al.,          )
                   defendants           )
________________________________________)

Upon consideration of the Motion to Compel Discovery, which was filed on behalf of plaintiffs, pro se, Concepcion Picciotto, White House Antinuclear Vigil, Scott Galindez, Sunrise S. Harmony, Ellen Thomas, William Thomas, Peace Park Antinuclear Vigil, Mary Huddle, and Philip Joseph, this ____ day of ________,

1989, it is hereby ORDERED:

That defendants shall provide plaintiffs with:

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), 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, 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, regul-ations, 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.

It is furthered ORDERED:

That nothing in this ORDER shall preclude plaintiffs from supplementing 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.

_________________________________
Joyce Hens Green
United States District Court

COPIES

Assistant U.S. Attorney
Michael Martinez
Judiciary Square,
555 4th Street N.W.,
Washington, D.C. 20001, and

Arthur Burger,
Assistant Corporation Counsel,
third floor, District Building,
1350 Pennsylvania Avenue, Washington, D.C. 20004.