THOMAS v. REAGAN

USDC Cr. No. 84-3552

Amended Complaint

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

WILLIAM THOMAS, Individually and representing

WHITE HOUSE ANTINUCLEAR VIGIL
1440 N Street, NW, #410
Washington, DC 20005
(202) 462-3542

CO-PEACE, INT'L
P.O. Box 27217
Washington, DC 20038
(202) 462-3542

and

HOMELESS ADVISORY COUNCIL
P.O. Box 27217
Washington, DC 20038
(202)462-3542

Plaintiffs Pro Se ("Plaintiff")

-versus-

GOVERNMENT OF THE UNITED STATES
by and though certain of its
REGULATORY and ENFORCEMENT AGENTS, to wit:

1

(1) WHITE HOUSE
1600 Pennsylvania Ave. NW
Washington, DC,
by and through

(1) Robert Bedell, Acting Administrator,
Office of Information and Regulatory Affairs,
Office or Management and Budget

(2) DEPARTMENT OF INTERIOR (DOI)

18th & C Streets, NW
Washington, DC,
by and through.

(a) DONALD P. HODEL, Secretary

(b) WILLIAM P. CLARK, Ex-Sec,

(c) JAMES WATT,Ex-Sec,

(3) NATIONAL PARK SERVICE (NPS)

1100 Ohio Drive, SW
Washington, DC by and through

(a) WILLIAM PENN MOTT, Dir.

(b) MANUS J. FISH, Reg. Dir.

(c) AD HOC WHITE HOUSE LIAISON
COMMITTEE ON PRESIDENT'S
PARK SIGNS,

by and through
JAMES McDANIEL, Ass.R.Dir.

(d) SANDRA ALLEY, Dir.Pub.Aff.

(e) CAROLYN O'HARE, Lf.Pk.Mgr.

(4) UNITED STATES PARK POLICE (USPP)

1100 Ohio Drive S.W.
Washington, D.C. by and through

(a) LYNN HERRING, Chief
(b) J.C. LINDSEY, Dep. Chief
(c) CHRISTOPHER MERILLAT, Lt

(5) UNITED STATES SECRET SERVICE
Executive Protective Service
White House Division
1600 Pennsylvania Ave. N.W.
Washington, D.C. by and through,
(a) JERRY PARR, Special Agent

(6) D.C. METROPOLITAN POLICE

District Building
Washington, D.C. by and through, (a) MICHAEL CANFIELD, Captain,

(7) ET AL,

Defendants

2

CA No. 84-3552
AMENDED COMPLAINT
Jury Trial Demanded

INDEX

I. Introduction
II. Jurisdiction
III. Parties
IV. FACTS
V. Summary, Causes of Action
VII. Summary of Counts
VII. Necessity for Relief
VIII. Prayer for Relief
Attachments
Additional Points & Authorities in Support or First Amended Complaint
Writ of Mandamus (Proposed)


Amended Complaint - Continued

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