Motion to Exclude Extra Judicial Materials

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.             |

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

In an Order, filed January 27, 1995, the Court granted Defendant's Motion for a Stay of Discovery.

In the interest of balanced jurisprudence, pursuant to the provisions of the applicable Federal Rule(s) of Civil Procedure and Evidence the Court may deem proper, plaintiffs hereby move the court, to enjoin defendants, or other agents acting on their behalf, from interrogating any plaintiffs, any witnesses for plaintiffs (including but not limited to: Wade Verner, David Jackson, Gregory Jackson or Daniel Jackson), or other potential witnesses about any incidents relating to the merits of this complaint, and particularly the incidents involving Officer O'Neill and Marcelino Corneil in Lafayette Park, prior the killing of Mr. Corneil across the street on the White House sidewalk, UNLESS plaintiffs, or a representative duly authorized by plaintiffs, are present at the interrogation, AND UNLESS, the interrogation is recorded in a manner consistant with the Federal Rules of Civil Procedure, the Federal Rules of Evidence.

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The reasons for this motion are explained in the accompanying Memorandum.

A proposed Order is attached.
Respectfully submitted,
______________________
William Thomas
2817 11th Street N.W.
Washington, D.C. 20005
202-462-0757

CERTIFICATE OF SERVICE

I hereby state that, on March 3, 1995, I delivered copy of the foregoing Plaintiff' Motion to Exclude Extra Judicial Materials Obtained by Agents Working to Afford Defendants Unfair Legal Advantage in the Instant Case upon the office of the United States Attorney, 555 4th Street NW, Washington, D.C. ROOM 10-808, by placing it in the U.S. mail, first class, postage prepaid

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