UNITED STATES DISTRICT COURT
Declaration of Randolf Myers
FOR THE DISTRICT OF COLUMBIA
William Thomas, et. al. | C.A. No. 94-2742
Plaintiffs pro se, | Judge Charles R. Richey
The United States, et. al. |
DECLARATION OF RANDOLPH J. MYERS
I, Randolph J. Myers, pursuant to 28 U.S.C. 9 1746,
depose and say as follows:
1. I am an Attorney in the National Capital Parks
Branch, Division of Conservation and Wildlife, Office of the
Solicitor, Department of the Interior.
2. As part of my duties I am responsible for legal matters
arising in connection with all programs and activities of
the National Capital Area of the National Park Service and the
United States Park Police. The National Capital Area includes the
Federal park land within the District of Columbia, and includes
3. On November 10, 1994, William Thomas wrote to
Assistant Solicitor Richard G. Robbins, asking whether Mr. Thomas'
signs in Lafayette Park conformed to National Park Service
regulations. Mr. Thomas also asked that if the signs did not
comply, what structural alterations would be necessary to bring it
into compliance with Park Service regulations. As part of my
responsibilities, Mr. Robbins assigned me to review and respond to
Mr. Thomas' inquiry.
4. In that regard, I reviewed the pertinent Park
Service regulations, regulatory history, as well as numerous
photographs of Mr. Thomas' earlier constructed signs taken
between October 8, 1988 and April 28, 1991. Further, I reviewed
photographs of Mr. Thomas' as well as Concepcion Picciotto's
signs that were taken on January 13, 1995.
5. I then responded in writing to Mr. Thomas' inquiry on
January 20, 1995, explained why the currently constructed signs
did not comply with the regulations and what structural
alterations would be necessary to bring it into compliance. This
letter, along with several photographs, was mailed postage
prepaid to Mr. Thomas on January 20, 1995. A copy of this letter,
which I adopt and affirm, is attached.
I declare under penalty of perjury that the foregoing is
true and correct to the best of my knowledge and belief. Executed
this 25th day of July, 1995.
RANDOLPH J. MYERS