28. Defendants' illegal and obstructive activities have included
unwarranted seizure, destruction of, or failure to return literature, tools, signs, and
camera; delay of presentment to Court (intended to cause plaintiff's incarceration);
assault; destruction of evidence; false testimony and/or obstruction of justice; police
harassment and intimidation; interference with practice of chosen profession and
religion, and deprivation of association through intimidation and/or arrest; false arrests,
or arrests without probable cause (under color of regulations, traditions, customs or
rituals) which resulted in dismissal, acquittal, and (one) bond forfeiture in fifteen. out of
twenty-two arrests; false imprisonment; lack of any clear definition of the terms
"camping" and "storage of property" (50.27) or "structure" (50.19), resulting in the
selective and discriminatory targeting of plaintiff and his associates
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to disrupt their legitimate, non-violent activities, refusal to define
the terms "casual sleep" and "storage of property" in response to plaintiff's request for
such definitions (pursuant to July 19, 1984 Order from this Court), additional overt
actions supporting the allegation of a conspiracy, especially perjurious, false ar
obstructive testimony to various Courts in the District of Columbia with the intent to
cause plaintiff's imprisonment. (See, inter alia, "Summary of Causes of Action,' para.
130·)
29. Notwithstanding any opposition defendants might have had to the ideas which
plaintiff has sought to communicate through words and actions, defendants knew or
should have known that plaintiff's rights as an individual were protected under the
Constitution to peacefully occupy space in a public park, disseminate ideas, and
display signs expressing dissent to the policies which defendants represent in their
official capacities.
30. Imaginary fears and impermissible prejudice aside, defendants cannot justify
their long term efforts to hamper, disrupt and terminate plaintiff's efforts to
communicate his peaceful ideas.
31. Already defendants' activities have effectively combined to cause plaintiff
irreparable injury by preventing him from maintaining a continuous expressive
presence in a public park, disrupting his legitimate, socially essential behavior, through
false statements to the press, and to further alienate certain elements of the public
from plaintiff's cause for peace and freedom. Unchecked, defendants' behavior in
suppressing plaintiff's rights will enable unquestioned and illegal activity by defendants
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and their agents as evidenced by defendants' most recent action in furtherance of their
conspiracy, the publication on August 20, 1983, of 36 CFR 50.19(e)(11).
32. Though repeatedly put on notice by plaintiff, the White House has persistently
refused to take action to halt this pattern of wrongful conduct. Until Robert Bedell's
response (attachment 1) to plaintiff's petition (attachment 2), the White House has
never responded to any of plaintiff's efforts to communicate, although responding to
others similarly situated.
33. Plaintiff respectfully seeks an Order from this Court which might enjoin
defendants from continuing to act in a way designed to interfere with plaintiff's First
Amendment rights, and intended to subject plaintiff to deprivation of other rights
guaranteed under the First, Fourth, Fifth, Ninth, and Fourteenth Amendments, and in
violation of 42 USC 1983, 1985(3); and Articles 1, 2, 3, 7, 9, 12; 18, 19, 20, 29 of the
Universal Declaration of Human Rights (UDHR) of the United Nations.
Amended Complaint - Continued
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