UNITED STATES DISTRICT COURT
Plaintiffs' Reply to Defendants Opposition to Motion to Exclude Extrajudicial Materials...
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. |
PLAINTIFFS' REPLY TO DEFENDANT'S OPPOSITION TO
PLAINTIFFS' MOTION TO EXCLUDE EXTRAJUDICIAL MATERIALS
OBTAINED BY AGENDTS WORKING TO AFFORD DEFENDANTS
UNFAIR LEGAL ADVANTAGE IN THE INSTANT CASE
On March 20, 1995 defendants filed an Opposition to
Plaintiffs Motion to Exclude Extra Judicial Materials (filed
March 3, 1995). Defendants correctly note,
"The incident involving the shooting of Mr. Corniel is nor before this
Court. The plaintiffs have raised claim. here that certain Park Police
officers have improperly enforced applicable regulations against the plaintiffs...."
Allegedly, the shooting of Mr. Corneil was a result of the
fact that "certain Park Police officers have improperly enforced
applicable regulations against the plaintiffs," and others
similarly situated. At bar plaintiffs assert the killing of Mr.
Corneil illustrates the logical end of a standardless enforcement
policy, which is capable of repetition yet continuously evades
the fact finding process. American Historical Assn. v. Peterson,
USDC CA. No. 94-2671, Decided, February 25, 1995; compare, cases
cited, Defendants' Motion to Dismiss, pg. 2, January 23, 1995.
To the extent that individuals from the criminal division of the
United States Attorney's office are conducting interviews as part
of an investigation, this litigation
should neither impede nor influence their investigation."
Opposition pg. 2.
Plaintiffs don't suggest that this litigation should impede
any legitimate criminal investigation. However, plaintiffs
maintain that information discovered in the course of those
investigations should not be accepted as "facts" in this case,
where plaintiffs have unrelentingly pressed for an evidentiary
hearing to ascertain the facts here.
"(C)ounsel is nor aware of any "defendants, ar other agents
acting on their behalf" conducting interviews of witnesses
for purposes of this litigation." Opposition, pgs 1 & 2.
If, indeed, defendants have no intention of predicating
their arguments in this case upon information obtained outside
the discovery process, under the pretext of investigating what
defendants assert to be an entirely different matter, there is no problem.
Respectfully submitted this __nd day of March, 1995
2817 11th Street N.W.
Washington, D.C. 20005
CERTIFICATE OF SERVICE
I hereby state that, on March 27, 1995, I delivered copy of
the foregoing Plaintiff' Reply to Defendants' Opposition to
"Plaintiffs' 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 HAND