696 F. Supp. 712-716

Expires 2/29/89


Dec 18, 1987

Date of the

1. Individual and/or organization sponsor(s)___________ W. Thomas and Ellen Thomas

Address(es) 1440 N ST. NW. #410, Washington DC 20005

Telephone Nos. (include area code) Day__ (202) 462-0757 ___ Evening _____462-0757

2. This is an application for a permit to conduct a DEMONSTRATION XX __ SPECIAL EVENT (For Definitions, see instructions.)

3. This is an application for a WAIVER OF THE NUMERICAL LIMITATIONS on certain demonstrations. Yes __ No X

(A waiver is required if it is expected that a demonstration on the White House Sidewall will include more than 750 participants or that a demonstration in Lafayette Park will include more than 3000 participants.)

4. Date(s) of proposed activity: From 12-21-87 To 12-28-87

Time: Begin: 00: 01 (am.) (pm) Terminate: 24: 00(am) (pm)

5. Location(s) of proposed activity. (Include assembly and disposal areas.) 24 sq. ft. on the south sidewalk of Lafayette Park, west of the center panel.

6. Purpose of proposed activity. To promote and demonstrate the resolution of conflict through patience, understanding and reason.

7. Estimated maximum number of participants. (If more than one park area is to be used, list numbers separately for each area three

8. Will cleanup people be provided for the area? yesXX ____ no. How will they be identified? By name (see above paragraph 1.)

9. Person(s) in charge of activity. (One person must be listed as in charge of the activity.

If different individuals are to be in charge of various activities at different locations, each must be listed.)

(The White House Sidewalk" is the sidewalk between East and West Executive Avenues, on the south side of Pennsylvania Avenue N.W.)

Person In charge W . Thomas

Address144O N St. NW #410, Washington. DC 20005

Telephone Nos. (Include area code) Day (202) 462-0757 Evening 412-0757

10. Plans for proposed activity. (Include a list of all principle speakers and the complete time schedule for the activity. Include proposed route of any march or parade, and plans for the orderly termination and dispersal of the proposed activity which might affect the regular flow of city traffic.)

We propose to demonstrate individual responsibility and moral commitment to our religious principle that "sin is to value one's own pleasure or comfort above the life of another by maintaining a continuous, 24-hour presence WITHOUT what might reasonably be considered living accommodations, to illustrate that the value of a human being is best measured by the being's spirit (i.e. soul/mind) rather than its monetary net worth. We will seek and/or welcome public dialogue at all hours, day and night.

NOTE: Our "presence" will be "continuous" excepting we will leave the Park area to wash, launder our clothes, prepare food, store personal property, and perform all eliminatory and other biological bodily functions. None of the aforesaid functions will be performed in the Park. We may engage in short-term, intermittent, INVOLUNTARY sleep during the course of our presence, but only as nature demands.

11. (a) List all props, stages, sound equipment, and other items to be provided by applicant/sponsor (Include approximate number and size(s) of supports, standards, and handles; necessary medical/sanitary facilities and other similar items.)
2 signs; 1 flag, 1 insulated bag per person (during cold weather, to be removed when not in use); literature (not to exceed 2,500 pieces at any one time); literature trays; one piece of 20 mm plastic (10 ft. X 12 ft.); pencils, pens, writing and editing materials (to be contained in one box measuring 4 in. X 6 in. X 18 in.); books (not to exceed 10); camera; tape recorder; umbrellas (1 per person); 1 water jug; 1 broom; 1 blanket per person to sit on; 1 plastic "Great Peace March" crate (12" x 12" x 18", approx.); no more food than might reasonably be consumed during a 24hour period.

(b) If boxes, crates, coffins, or similar item will be used, state whether they are to be carries opened or closed, their proposed size, the materials constructed from, and their proposed contend and-use.small speakers platform

12. (a) Do you have any reason to believe or any information indicating that any individual group, or organization might seek to disrupt the activity for which this application is submitted?Yes.

(b) If YES, list each such individual, group, or organization, with all information as to each, including address and telephone numbers.

Washington TIMES (and/or the Unification Church) 3600 New York Avenue NE, Washington, D.C. Upon information published and from personal experience we believe this organ will place our form above our substance and attempt to disrupt our activities by telling the public that we are ugly and "Anti-American" became of editorial ideological opposition to the substance of our message.

Young Americana for Freedom, national headquarters in Wilmington, Delaware, precise local address currently unknown. Upon personal experience we believe members of this organization may resort to actual physical violence against us because of ideological opposition to the substance of our message.

Nevertheless, in spite of potential unpleasantness, we do not require any special protection or surveillance, convinced, (from experience) that God, and our commitment to nonviolence as the only path to peace, protect us.

18. Marshals: (a) Will applicant/sponsor furnish marshals? (Required for waivers of numerical limitations and for demonstration activities held simultaneously on the White House sidewalk and Lafayette Park.) Yes _ No X If YES how many marshals will be furnished?

(b) Person(s) responsible for supervision of marshals (for each location): Location(s) Not applicable.


Position of person filing application:MIDDLE OF THE ROAD
Signature of person filing application: /s/ W. Thomas
Telephone Nos. of person filing application: Day462-0757 Evening Same

Typed or printed name of person filing application: W. Thomas

Address of person filing application: , 1440 N St. NW # 410, D.C. 20005


United States Department of the Interior


Date: December 21, 1987

In accordance with Park Regulations as contained in C.F.R, Title 36, Chapter 1, Section 50.19, permission is granted to conduct a public gathering to the following:

W. Thomas and Ellen Thomas

(Person(s) and, or Organization(s)

Date(s) __December 21, 1987 to December 21 1987

Time: Starting:12:01 a.m. Ending:1:59P.m. (continuous)

Location(s)24 sq. ft. on the south sidewalk of Lafayette Park, west of the center panel.

Purpose(s)To promote and demonstrate the resolution of conflict through Patience understanding and reason.

Anticipated Number of Participants: 3

Person(s) in Charge W. Thomas

Address(es) 1440 N St., NW # 410, Washington, D.C. 20005

Telephone Nos. Day:462-0757 Evening: 462-0757

This Permit is Granted subject to the following conditions:

Permittee and all participants authorized herein must comply with all of the conditions of this permit and with all reasonable directions of the United States Park Police.

All sidewalks, walkways, and roadways must remain unobstructed to allow for the reasonable use of these areas by pedestrians, vehicles, and other park visitors. PLEASE READ ATTACHED REGULATIONS REGARDING SIGNS & STRUCTURES IN LAFAYETTE PARK AND ADDITIONAL PERMIT CONDITIONS APPLICABLE TO YOUR DEMONSTRATION ACTIVITIES.

All laws, rules, and regulations applicable to the area covered by this permit remain in effect.

No fee may be collected, donations solicited, nor commercial activity conducted, and no articles, except those expressing views through printed matter, such as newspapers, pamphlets, posters, buttons, or bumper stickers, may be offered for sale.

The area must be left in substantially the same condition as it was prior to the activities authorized herein, and all litter shall be placed in the trash containers provided.

6. This permit is applicable only for the use of the area designated above, and during the times designated above, or in any area as may hereafter be designated by the United States Park Police.

7. The use of sound amplification equipment, other than hand-portable sound amplification equipment to be used for crowd control purposes only, is prohibited on the White House Sidewalk (South 1600 Pennsylvania Avenue, N.W., sidewalk between East Executive Avenue and West Executive Avenue). All sound amplification equipment shall be limited so that it will not unreasonably disturb nonparticipating persons in, or in the vicinity of, the area.

8. The National Park Service reserves the right to immediately revoke this permit at any time should it reasonably appear that the public gathering presents a clear and present danger to the public safety, good order or health, or if any conditions of this permit are violated.

Manus J. Fish
Regional Director,
National Capital Region
By [Illegible] for Al Dale
Chief, Division of Public Events

United States Department of the Interior


This is to notify you of restrictions applicable to your demonstration activities. Whether you are demonstrating under permit or Pursuant to the small-group exemption to permit requirements, you must comply with regulations applicable to park lands and Demonstration found at 36 C.F.R Parts 1 through T. We would especially note the following that are prohibited in all park areas:

1. Injuring federal property, including snow fencing, grass, and other vegetation or structures (See 36 C F.R. 2.1(a) and 2.31);

2. Failing to have dogs or cats entirely under control and caged or on a leash not more than six feet long (See 36 C.F.R. 2.15); and

3. Camping or using park land for living accommodation purposes (See 36 C.F.R. 7.96(i)).

Further, special regulations applicable to Lafayette Park, found at 36 C.F.R. 7.96(g)(5)(x), impose additional restrictions on demonstrations in that park area. These regulations restrict the size, number, and use of stationary signs in Lafayette Park and prohibit the use of structures, except certain speaker's platform's, there. These regulations should be carefully studied before carrying on a demonstration in Lafayette Park.

In addition, pursuant to 36 C.F.R 7.96(g)(5)(xii)(B) and 7.96(g)(5)(xiii), the Regional Director, National Capital Parks, imposes the following additional conditions on all demonstrations occurring in Lafayette Park:

1. Property may not be stored in the Park, including, but not limited to construction materials, lumber, paint, tools, household items, food, tarps, bedding, blankets, sleeping bags, luggage, and other personal property. (In this regard, certain personal property that is reasonably required by a demonstration participant during any one 24-hour period will not be considered to violate this permit condition. Such property may include items such as a coat, a thermos, and a small quantity of literature. However, the quantity of these items may not exceed that which is reasonably necessary in a 24-hour period);

2. Signs or other objects may not be attached to lamp posts, trees, or structures in the Park;

3. Construction activities, including, but not limited to painting of signs, may not be undertaken in the Park;

4. All materials, used in demonstration activities must be safe for use in public areas for example, signs must be held or secured so as not to fall on pedestrians and supports must not pose a tripping, or other hazard;

Sound equipment may not be used at such a volume as to unreasonably disturb nonparticipating persons in the area;

Activity on the sidewalks must allow for an eight foot clearance for the passage of pedestrians, emergency vehicles, and trash removal carts;

Activities on the sidewalks may not result in damage to or loosening of sidewalk bricks, such prohibited active include but are not limited to: staking, chipping, nailing or wedging materials to or between bricks;

Activities may not obstruct access to park benches, trash receptacles or adjacent lawn areas; and

Demonstrators will be required to move their materials Upon the request of National Park Service personnel when park maintenance is necessary.

If you have questions regarding these regulations or permit conditions, please contact Sandra Alley, Associate regional Director, Public Affairs, at 485-9666, or Rick Merryman on her staff at 486-9660.

/s/Al Dale

Associated Regional Director Public Affairs


For the reasons stated in the memoranda filed on February 23, 1984, and on today's date, it is this 16th day of September, 1988, hereby

ORDERED: that the complaints in Civil Action No. 84-3552-LFO and Civil Action No. 87-1820-LFO should be, and are hereby, dismissed without prejudice.