UNITED STATES DISTRICT COURT
Declaration of William Thomas in support of Motion to Strike
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 WILLIAM THOMAS IN SUPPORT OF
PLAINTIFFS' MOTION TO STRIKE
RANDY MEYERS' LETTER OF JANUARY 20, 1995
FROM THE RECORD
I, William Thomas, hereby declare under penalty of perjury that the following is true and correct to the best of my knowledge and understanding:
1. In my November 10th letter to Mr. Robbins, I wrote:
"(I)n the unlikely event that you too think this "sign" is a "structure" under
the applicable regulatory provisions, please specify the precise structural
alterations you believe would be required to bring the "structure" into compliance
as a "sign." ADDITIONALLY, PLEASE MAKE THAT INFORMATION
AVAILABLE TO ME AS SOON AS POSSIBLE SO WE CAN DISCUSS
POSSIBLE CORRECTIVE MEASURES THEREBY AVOIDING A BASELESS
ARREST, AND THE UNNECESSARY DISRUPTION OF MY RELIGIOUS
Declaration of William Thomas in Support of the Complaint, Exhibit 1, pg. 2.
2. The intent of my letter to Mr. Robbins was to arrive at an understanding that would enable us to continue our harmless
expressive activities, as effectively as possible, while avoiding, arrest, threats, intimidation, criminal, or civil, litigation.
3. Too late, on January 23, 1995 I received Defendants' Opposition to Plaintiffs' Motion to Reconsider Denial of Plaintiffs' Application for a TRO, or Alternatively to Dismiss the Complaint as Frivolous. Attached to Defendants Opposition was a letter, dated January 20, 1995, from Randy Meyers,
Assistant Solicitor, DOI, which identified itself as a " response to [my] letter to Richard Robbins dated November 10, 1994."
4. Several hours later I went to my post office box, and discovered an original of the same letter, which had been sent to me through the mail.
5. I don't consider Mr. Meyers' letter as a response to my letter to Richard Robbins. My letter to Mr. Robbins was an attempt to avoid trouble and resolve a problem; from my point of view quick some time after the trouble, which could have been avoided, materialized; this letter looking more like an ex post facto prohibition than a response to the problem I was trying to avoid.
January 27, 1995