MARY HUDDLE and PHILIP JOSEPH, et. al., )
plaintiffs, )
)
versus ) CA 88-3130-JHG
) Judge Joyce Hens
RONALD WILSON REAGAN, et. al., )
defendants )
________________________________________)
Prompted by Federal Defendants' Notice to the Court, October 2, 1989, on October 13, 1989 plaintiffs filed a Notice, a Reply to the Federal Defendants' Notice, and the 3rd Declaration of William Thomas.
As plaintiffs understand it the question before the Court is whether this suit should be dismissed suit de jure, as defendants urge, or considered de facto, because plain-tiffs assert that - in order to remain civilized - a society must provide some workable mechanism to ascertain fact, guard against injustice, ensure equal protection under law, and shield harmless truth-seekers against persecution. See Reply page 1.
Owing to the haste of William Thomas, his 3rd Declaration may not have sufficiently made the connection between truth-seeking and plaintiffs' continuous presence in Lafayette Park.
Wherefore plaintiffs move to supplement the 3rd Declaration of William Thomas with a 4th Declaration.
Respectfully submitted,
_____________________________
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 )
________________________________________)
I, William Thomas, hereby declare under penalty of perjury that the following is a true and accurate representation of my beliefs and understanding:
1. In my 3rd Declaration I attempted to define the term "actual (elemental) reality" (see, United States v. Thomas, 864 F.2d at 192), and how a continuous presence in Lafayette Park facilitates the process of understanding "actual reality."
2. "Actual reality" is synonymous with "truth." Thus "the clarification of actual reality" (id) would be synonymous with "truth-seeking." See 3rd Declaration, para. 5.
3. Well established religious authority values truth. E.g., "know the truth and the truth and the truth shall make you free." John 8: 32.
4. "Actual reality" is to "individual perspec-tive of reality" as "truth" is to "personal opinion." I do not claim to know the truth, only to believe that by reasoning together individuals enter into a process with the potential to refine individual perspectives thus bringing the parti-cipants closer to understanding the truth.
5. The process of in depth reasoning often challenges deeply ingrained personal opinions, beliefs, or prejudices. Consequently it re-quires considerable time and patience.
6. Early one morning in the summer of 1981, at about 1:00 AM, several students from George Washington University stopped to speak with me on the White House sidewalk. After approximately one-half hour I made a critical comment about one student's choice of a career. Because of my comment the student became irate, and they all left.
7. Nearly six months later that same student again approached me on the White House sidewalk, and introduced himself as Joe Tanzi. Mr. Tanzi told me that he had been very angered by what I had said, but thought about our conversation after he left. "I don't agree with everything you say, or maybe I just don't understand it," he told me, "but after I thought about it I realized that I did agree with a lot of what you said." He told me that he had returned to discuss some things further. Over the years I met with Mr. Tanzi on at least three additional occasions in the White House/Lafayette Park area.
8. This is only one example of a typical experience.
9. In these days when a call for a basic re-examination of "values" echoes across the spectrum of religious and political leadership, through my continuous presence I intend to symbolize committment to the belief that the spiritual and physical secur-ity of any culture begins and ends upon the value of life. Upon ancient authority my spiritual values are based on the premise that, "God is life" (e.g. John 1: 1-4), and the practical premise that I must love "(my) neighbor, as (my)self" (e.g. Leviticus 19:18, Matthew 22: 39), because if one doesn't love the visible brother, one cannot reasonably love the invisible God. 1 John 4: 20. Hence, I believe it Godly to prac-tice reason and under-standing while abstaining from force and violence.
10. Those who wish to ignore me as they transit Lafayette Park are free to do so; however, in addition to the symbolic significance of my presence in the park, there is the practical significance of being available to those who may wish to come and reason together in pursuit of truth.
11. As long as I caused no harm, prior the promulgation of the regulaitons at issue here, police officials had no legal authority by which to justify forceful interference with my truth-seeking process.
12. Subsequent to the promulgation of the regulations at issue, police officials have been able to apply the regulations as a tool to punish my harmless activities.
Under penalty of perjury,
_____________________________
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 )
________________________________________)
I William Thomas, hereby state that, on this 18th day of October, 1989 I caused true copies of Plaintiffs' Motion for Leave to file the 4th Declaration of William Thomas and the 4th Dclaration of William Thomas 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 to the office of Arthur Burger, Assistant Corporation Counsel, third floor, District Building, 1350 Pennsylvania Avenue, Washington, D.C. 20004.
_____________________________
William Thomas