THOMAS v. REAGAN

USDC Cr. No. 84-3552

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

WILLIAM THOMAS, pro se,         
                Plaintiff,    
     v.                               Civil Action No. 84-3552
                                    (Judge Louis Oberdorfer)

UNITED STATES, et al.,
                Defendants.

FEDERAL DEFENDANTS' MOTION FOR JUDGMENT ON THE ADMINISTRATIVE RECORD

The federal defendants, by and through their undersigned counsel, hereby move pursuant to Fed. R. Civ. P. 7(b)(l) for judgment on the administrative record insofar as the plaintiff challenges the National Park Service's recently published Lafayette Park regulation, 51 Fed. Reg. 7556 (March 5, 1986). Reasons in support of this motion are set forth in the attached memorandum of law which also opposes plaintiff's motion for preliminary injunction. Also attached is a Statement of Material Facts, which is submitted as an aid to the Court to help focus

the administrative record in this matter. That record was filed with the Court on March 17, 1986. Finally a proposed order is also attached.

Respectfully submitted,

JOSEPH E. DIGENOVA, DC BAR #073320

United States Attorney

ROYCE C. LAMBERTH, DC

Assistant United States Attorney

(signed)

JOHN D. BATES, DC

Assistant United States Attorney

(signed)

MICHAEL L. MARTINEZ, DC

Assistant United States Attorney

Memorandum

Contents

Case Listing --- Proposition One ---- Peace Park