UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.,
             Plaintiff,

          v.                        Civil Action 88-3130 JHG
                                    Judge Joyce Hens Green
RONALD WILSON REAGAN, et al.,
             Defendant.

PLAINTIFF ELLEN THOMAS' MOTION TO SUPPLEMENT
THE REPRESENTATION OF PLAINTIFFS' CONSTITUTIONAL CLAIMS
AGAINST THE REGULATIONS AT ISSUE

During the hearing held in this matter on December 7, 1989, I thought that the Court asked a very important question relating to our Constitutional claims and the regulations at issue here.

The answer offered by William Thomas, who plaintiffs have agreed should act as spokesman for all of us, was not satisfac-tory to me. In the courtroom I asked Thomas to clarify his response to the Court, but he failed to do so, later explaining that he was over-anxious to have Mr. Robbins testify. See, Plaintiff's Motion to Expedite the Hearing on Plaintiffs' Appli-cation for a Temporary Restraining Order and Motion for Prelim-inary Injunction, filed November 21, 1989, footnote 6.

Because I consider the Court's question about our specific claims to be crucial, I would like to make certain that our claims are clear.

I. THE LAFAYETTE PARK REGULATION

36 CFR 9.76(g)(5)(x)(A)(1)(2)(3)(4)(B)(1) and (2), formerly codified at 36 CFR 50.19(e(11)(12), is both unconstitutional, having been promulgated under false pretences and for unconstitutional reasons, and has been been unconstitutionally applied. See, Amended Complaint, filed November 23, 1988, para. 42, see also, e.g., Summarization of Complaint, filed November 21, 1989, e.g. paras. 31, 54, 63, 67; Plaintiffs' Memorandum in Support of their Application for a Temporary Restraining Order and Motion for Preliminary Injunction, filed November 21, 1989, pages 6-9; Plaintiffs' (Redacted) Response to Federal Defendants' Supplemental Motion to Dismiss, filed January 17, 1989, page 15; Complaint, filed September 30, 1988, paras 20, 56, 79.

II. THE CAMPING REGULATION

36 CFR 9,76(i) and 36 CFR 9.76(g)(5)(vii)(2), formerly cod-ified at 36 CFR 50.27(a) and 36 CFR 50.19( ).

We do not challenge the constitutionality of this regula-tion. Our sole contention is that this regulation has been unconstitu-tionally applied against us, and we seek relief from that application. See, Amended Complaint, filed November 23, 1988, para. 42, see also, e.g., Summarization of Complaint, filed November 21, 1989, e.g. paras. 55, 63, 69; Plaintiffs' Memorandum in Sup-port of Their Application for a Temporary Restraining Order and Motion for Preliminary Injunction, filed November 21, 1989, pages 14, 15; Plaintiffs' (Redacted) Response to Federal Defendants' Supplemental Motion to Dismiss, filed January 17, 1989, page 11.

III. THE WHITE HOUSE SIDEWALK REGULATION

36 CFR 9.76(g)(5)(viii) and (ix), formerly codified at 36 CFR 50.19(e(9)(10),

We make no claims for relief under this regulation, but consider it to be important evidentiarily. See, Complaint, filed September 30, 1988, paras. 20, 35, 78; see also, e.g., Summariza-tion of Com-plaint, filed November 21, 1989, e.g. para. 30; Plain-tiffs' Memorandum in Sup-port of Their Application for a Temporary Re-straining Order and Motion for Preliminary Injunction, filed November 21, 1989, pages 10, 11; Plaintiffs' (Redacted) Response to Federal Defend-ants' Supplemental Motion to Dismiss, filed January 17, 1989, pages 11, 12.

Respectfully submitted,

Ellen Thomas
1440 N Street, N.W. Apt. 410
Washington, D.C. 20038
202-462-0757

CERTIFICATE OF SERVICE

I Ellen Thomas, hereby state that, on this ___ day of December, 1989 I caused a true copy of the foregoing Plaintiff Ellen Thomas' Notice to the Court to be hand-delivered to the offices of U.S. Attorney Michael Martinez at Judiciary Square, 555 4th Street N.W., Washington, D.C., and the Office of the Corporation Counsel for the District of Columbia, 1250 Pennsylvania Avenue, N.W., Washington, D.C.

_____________________________
Ellen Thomas