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Exhibit 15

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for the first time in history the nation's most important address is no longer safe.

References: Plaintiff's Exhibits 1-9.

Segment: 5
Tape Time: 1m 22s - 2m 27s
Source: NBC
Date: May 24, 1995

Topic: Effect upon District Businesses and Residents
Location: Pennsylvania Avenue, City Council Chambers
Activity: Dave Clark Speaking, Anthony Martin Speaking, Secret Service Meeting with City Council

Dialogue: [NBC] (Secret) Service cannot arbitrarily and permanently close Pennsylvania Avenue without due process of law.

[Dave Clark] If something is needed because of the Federal presence in the District of Columbia, including the presence of the President of the United States, then the people of the District of Columbia and its businesses must be considered in the doing of that action.

[NBC] Clark said the abrupt shutdown destroys business for some vendors and tourbuses.

[Dave Clark] Wiped out, I'm not talking about just inconvenienced, their businesses are wiped out.

[NBC] Secret Service officials who met privately with Council members earlier in the week declined to participate today. They say they can override local and federal laws to protect the president. Local attorney Anthony Martin disagrees. He filed a Freedom of Information Act request to get background on the closing, and says he'll sue if necessary to reopen the avenue.

[Anthony Martin] We have a situation where they acted in the stealth of night. A rather outrageous and improper situation.

Location: Pennsylvania Avenue
Activity: Scenes of Closed areas, Security Forces, Barricades

Dialogue: [Thomas] Yesterday this was a major thoroughfare, the symbol of our Free and Democratic Nation. Today it is the haunt of Security Forces.

[3m 48s] (Barricade on Pennsylvania Avenue and 17th St.)
[Thomas] The view from the other direction, West of the barriers, we see the three tiers of barriers and small opening for vehicle entry and exit.

[4m 30s] (Barricades on Pennsylvania Avenue from 15th St and Madison Pl)
[Thomas] In fact now we see if this vehicle probably has police officers in it, we might be able to circumnavigate this area here. As we can see this is a police vehicle by the policeman in it.

[4m 55s] Now we are coming up on the second set of barricades here. There's one of them right over there, one of those busses. Busses are being permitted to come down here.

[5m 20s] And here we have the entrance way. And a shot coming from the East to West. Shot of the Hockey players, not to busy today.

[5m 43s] We just zip back around here and look at the situation from this side. Here's the area that's ingress and egress for motor vehicles. So if we had a caravan of say 50,000 camels, they wouldn't be able to fit through there without too much trouble. That's the East Gate of the White House.

[6m 14s] (Jackson Place) Jackson Place enclosed off.

[6m 22s] (H and 16th St.)

[6m 32s] (H and Madison Pl)

Dialogue:

[Thomas] In fact we are improving intellectual commerce in the United States.

[Ellen] Can you explain what it is you are doing here?

[Thomas] We are communicating as effectively as possible. We wish for a wise and honest government.

[Ellen] Do you have authority to have this sign here in front of the White House ?

[Thomas] The First Amendment of the Constitution guarantees that Congress shall pass no law respecting the establishment of religion, Free exercise thereof, Freedom of Speech, Freedom of the Press, or the Right of the people to peaceable assemble and petition the Government for redress of grievances. We're doing all those things, that's our authority.

[Thomas] I'm trying to communicate. In order to communicate, to be noticed, is the first thing. So by having the sign right here, people who want to take pictures of the sign will be able to take pictures and show the words on the other side of the sign to all their friends back home. If they don't want to take pictures of the sign, they can just stand on the side where you are and take pictures of the house without the sign in it. So this gives everyone freedom of choice and gives me an opportunity to communicate as effectively as I can under the very limited resources that are available.

Activity: Thomas Informing Officer of Demonstration Regulation, DC Officer Radzilowski misinforming Thomas of Regulations.

Dialogue:

[Thomas] Demonstrations are allowed on public space as long as you are not obstructing traffic...Why do I have to move, do you have a regulation?

[8m 38s]
[Radzilowski] DCMR [District of Columbia Municipal Regulations]

[Thomas] Which one?

[Radzilowski] I'm not going to argue with you, I'll give you all forty of them, If you don't move we're going to take this thing and lock you up.

[Thomas] Your order is only lawful presuming you have a law that you are enforcing.

[Radzilowski] Discussion is over

[Thomas] What you don't understand is...

[Concepcion Picciotto] The police they come every day and take us.

[8m 58s] [Showing in background another demonstrator with sign leaning against him, on Pennsylvania Avenue]

[Thomas] You can't just tell people to do things if they aren't doing anything wrong. You're a law enforcement officer, you can only enforce the law. You can't impose tyranny upon people, because it's not lawful.

[9m 35s] This probably isn't even your idea, it's probably the Secret Service idea, they told to do this. But you ain't got a leg to stand on legally, I don't think, I really think..

[Radzilowski] We shall see won't we.

[Thomas] We will ... and you should get yourself some legal advice, I think, with all do respect, I think you should get yourself some legal advice before you do this.

[Radzilowski] No problem.

[Thomas] You'll do that then, you will contact the solicitor before you...

[Radzilowski] No.

[Thomas] OK.

6

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[Radzilowski] (Do you have) somebody to take your sign for us not to take it. Who's that?...

[Radzilowski] Our discussion is over, I gave you a lawful order to do something and you refused, that's all I need to know, that's all the judge needs to know

[Thomas] If you would give me the citation for your authority, if you would tell me where it says that I can't have a sign in this location

[Radzilowski] DCMR

[Thomas] Where?

[Radzilowski] Get your attorney to look at it

[Thomas] Since I'm not aware of it, and since the Corporation Council has given me different opinion, and since you refuse to tell the number, I don't think I need to call my lawyer.

[11m 40s] (Shows Officer Radzilowski talking to the other demonstrator, who then moves his sign to the sidewalk)

[Thomas] Apparently demonstrating how lawless the country is. This Lt. (Captain) here from the District of Columbia told me I had to...

[DC Police Officer] You did a good job. (To other officers.)

[Another DC Police Officer] Are you going to get up and walk?

[12m 55s] (Shows Officers carrying unresisting Thomas from sign to Transport Vehicle.)

[Officer] Hey folks, why don't we stay back...
[Another Officer] I need everyone to clear the area.

Activity: White House Running Club Exercising in front of White House using entire width of Pennsylvania Avenue

Dialogue: (Singing of Father Abraham)

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