Untitled Document

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et. al.,
            Plaintiffs,

          v.                     Civil Action No. 88-3130 
                                 Judge Joyce Hens Green
RONALD WILSON REAGAN, et. al.,
             Defendants.

PLAINTIFF'S MOTION TO EXPEDITE DISCOVERY

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.

Plaintiffs believe that they are entitled to the requested information, and that the interest" of justice can only be served if they are provided with these documents prior to the hearing for a preliminary injunction in this case.

Therefore plaintiffs hereby pray this Court to compel defendants, on an expedited basis, to provide plaintiffs with:

1) All case incident or arrest reports which have been generated since January 12, 1991 within the possession, custody or control of the U.S. Park Police, National Park Service, or the Department of Interior, relating to any or all plaintiffs and demonstration activities involving Lafayette Park.

2) All photographs, video and audio tapes which have been generated since January 12, 1991 within the possession, custody or control of the U.S. Park Police, National Park Service, or the Department of Interior, relating to any or all plaintiff-.

4) All United States Park Police memoranda, regulations, or directives respecting the enforcement of 36 CFR Section" 7.96 (i) (1).

5) Any interdepartmental written directives, memoranda, orders, or other communications any agency of the Park Police, the Interior Department, the Secret Service, National Park Service, or the White House regarding enforcement of the "camping" regulation,

6) The substance of oral instructions, if any, given to Park Police Officers with respect to the "camping" regulation,

7) Any and all note" of observations, including case incident reports, criminal reports, or any other writings. concerning any or all plaintiffs and/or their activities in Lafayette Park generated by officers of the United States Park Police from January 12, 1991 to the present.

8) Copies of Park Police radio communications for the District One and Anacostia substations from January 12, 1991 to the present.

9) All documents in the possession of the National Park Service and the U.S. Park Police relating to demonstrations in Lafayette Park since January 12, 1991.

10) Pictures, with badge numbers and names of all Park Police officers, including members of the equestrian squad, assigned to any duties in or near Lafayette Park since January 12, 1991.

11) List of all Park Police and District of Columbia Metropolitan police assigned to any duties in or around the park on January 12, 1991.

12) Park Police command structure which was in place between the hours of 2 to 10 PM February 24, 1991.

13) Every incident of enforcement of 36 CFR 2.12 within the District of Columbia.

14) Plaintiffs ask for leave of Court to supplement these requests as plaintiffs' investigation may indicate the existence of discoverable evidence.

CONCLUSION

Wherefore, as the requested materials are integral to the matters subject their motion for a preliminary injunction, plaintiffs hereby move for an Order compelling defendant" to supply the requested material.

Respectfully submitted this 15 th
day of APRIL , 1991,

William Thomas, pro se
2817 11th Street, N.W.
Washington, D.C. 20001
(202) 462-0757

CERTIFICATE OF SERVICE

I, William Thomas , hereby state that, on this 15th day of April, 1991 I caused a copy of the foregoing Plaintiffs' Motion to Expedite Discovery to be hand-delivered to the offices of Jay B. Stevens, U.S. Attorney for the District of Columbia at Judiciary Square, 555 4th Street N.W., Washington, D.C., and the Office of the Corporation Counsel for the District of Columbia

/s/W. Thomas

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

Huddle, et. al.
Plaintiffs pro se

v. C.A. No. 88-3130
Judge Joyce Hens Green
Reagan, et. al.
Defendants.

ORDER

Upon consideration of the Motion to Compel Discovery, which was filed on behalf of plaintiffs, pro se, this day of , 1991, it is hereby ORDERED:

That defendants shall provide plaintiffs with:

4) All United States Park Police memoranda, regulation", or directives respecting the enforcement of 36 CFR Sections 7.96 (i) (1).

5) Any interdepartmental written directives, memoranda, orders, or other communications between any agency of the Park Police, the Interior Departement, the Secret Service, National Park Service, or the White House regarding enforcement of the "camping" regulation.

6) The substance of oral instructions, if any, given to Park Police Officers with respect to the "camping" regulation,

7) Any and all notes of observations, including case incident reports, criminal reports, or any other writings concerning any or all plaintiffs and/or their activities in Lafayette Park generated by officers of the United States Park Police from January 12, 1991 to the present.

8) Copies of Park Police radio communications for the District One and Anacostia substations from January 12, 1991 to the present.

9) All documents in the possession of the National Park Service and the U.S. Park Police relating to demonstrations in Lafayette Park since January 12, 1991.

10) Pictures, with badge numbers and names of all Park Police officers, including members of the equestrian squad, assigned to any duties in or near Lafayette Park since January 12, 1991.

11) List of all Park Police and District of Columbia Metropolitan police assigned to any duties in or around the park on January 12, 1991.

12) Park Police command structure which was in place between the hours of 2 to 10 PM February 24, 1991.

13) Every incident of enforcement action relating to 36CFR 2.12 within the District of Columbia.

It is furthered ORDERED:

That nothing in this ORDER shall preclude plaintiffs supplementing these requests as plaintiffs' investigation may indicate the existence of additional discoverable evidence.

Joyce Hens Green
United States District Court

COPIES OF THIS ORDER SHOULD BE ADDRESSED TO:

Jay B. Stevens, U.S. Attorney
Judiciary Square
555 4th Street N.W.,
Washington, D.C. 20001

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

William Thomas
2817 11th Street, N.W.
Washington, D.C. 20001

Office of the Corporation Counsel
District Building 3rd floor
Pennsylvania Avenue, N.W.
Washington, D.C.