Third Declaration of William Thomas

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


     William Thomas, et. al.       |          C.A. No. 94-2742
           Plaintiffs pro se,      |          Judge Charles R. Richey
                                   |
               v.                  |
                                   |
     The United States, et. al.    |
           Defendants.             |

DECLARATION OF WILLIAM THOMAS IN SUPPORT OF
PLAINTIFFS' MOTION TO EXCLUDE EXTRA JUDICIAL MATERIALS
OBTAINED BY AGENTS WORKING TO AFFORD DEFENDANTS
UNFAIR LEGAL ADVANTAGE IN THE INSTANT CASE

I, William Thomas, hereby declare under penalty of perjury that the following is true and accurate to the best of my knowledge and recollection:

  1. On January 31, 1995 Concepcion Picciotto told me that she had been approached earlier in the afternoon by two unidentified police officers in a white unmarked car.


  2. I was told by several different people that the two officers had also been asking about the whereabouts of Wade Varner.


  3. On December 20, 1994, I had seen Mr. Varner about three hours after the shooting, when he got out of an unmarked police vehicle. At that time he told me had given sworn statements to D.C. Homicide about the shooting.


  4. Additionally, I was also told by two or three different people that the police officers also asked about the Jackson brothers (Gregory, David and Daniel.


  5. Finally, I was told they left the Park with William Pugh in their vehicle. Several hours later I saw a white unmarked car stop at the curb on the south side of the Park, and Willism Pugh step
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    out of it.


  6. On or about February 1, 1995, I contacted beeper number 202-515-1957 and was eventually connect with a woman who identified herself as Lt. Crockett, Metropolitan Police, Homicide Division.


  7. I told Lt. Crockett was concerned that the police might be planning to take her into custody for questioning.


  8. When Lt. Crockett asked who I was, I told her that I was Concepcion's friend, and that Concepcion had asked me to try to determine what the police were planning with respect to her.


  9. Lt. Crockett said that D.C. Homicide only interested in talking to her about the shooting of Marcelino Corneil.


  10. I told her that Concepcion was also concerned about the effetst discussing that incident might have on other litigation she was involved with.


  11. "We don't want to talk to her about the civil case, we just want to ask her some questions about the shooting."


  12. "You know about the civil case?" I asked.


  13. "Yes, but we're not interested in that. We only want to ask her about the shooting." Lt. Crockett said.


  14. "But, the incidents directly proceeding the shooting are at the heart of the civil suit." I said.


  15. At that point Lt. Crockett seemed to become somewhat defensive, and began to accuse me of trying to make something out of nothing. I allowed her to talk until a lull in her delivery, when I told her that I hoped she did not think that I was trying to be hostile, because my only reason for calling was to calm
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    concepcion's concerns over whether or not a warrent would be issued for her arrest if she continued to refuse to submit to questioning. Lt. Crockett said, "No we will not do that. If Ms. Picciotto does not want to talk to us, she doesn't have to."


  16. I thanked her and said I would convey that information to Concepcion, which I did.


  17. Upon sound information, on or about March 2, 1995 Assistant U.S. Attorney Eric Marcy, accompanied by other presently unidentified agents from presently unidentifed Governent agencies appeared in Lafayette Park to question various individuals, including, but not limited to Ellen Thomas, David (see, Declaration of David Jackson, filed February 24, 1995, Plaintiffs' Motion to Reschedule Preliminary Injunction Hearing, Exhibit 3), Gregory Jackson. It is reported that Mr. Marcy also questioned other people who may or may not (some of whom may not have, but said they did) personally observed information concerning the incidents which preceded the Mr. Corneil's shooting on the White House sidewalk.


Respectfully submitted,

______________________
William Thomas
2817 11th Street N.W.
Washington, D.C. 20005
202-462-0757
March 3, 1995

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