USDC Cr. No. 84-3552
THOMAS v. REAGAN
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
vs. CA No. 84-3552
Judge Louis Oberdorfer
UNITED STATES OF AMERICA, et. al. Magistrate Arthur Burnett
PLAINTIFF'S DECLARATION CONCERNING DECEMBER 10. 11 1981,
THE EVOLUTION OF PLAINTIFF'S LARGE SIGNS,
THE PLACEMENT OF LARGE SIGNS IN LAFAYETTE PARK,
AND THE EVENTS SURROUNDING SEPTEMBER 24, 1983
I, William Thomas, plaintiff pro se in the above entitled
action, hereby declare, under penalty of perjury, that the
following statements are true and correct to the best of my
1. On June 3, 1981, I began an expressive action in front of
the White House, on the south sidewalk of Pennsylvania Avenue, in
Lafayette Park. At that time I had two small cardboard signs. One
sign read: "Wanted Wisdom and Honesty," the other sign read
2. My intent with regard to that action was to communicate
my opinion that "moral perfection is impossible for a member of an
immoral nation-state," and to "encourage those who understand the
meaning of my words to gather at the White House to pray for Peace,
Sanity, and an End to War in illustration of the Ideals of
non-violence." (Complaint Attachment .)
3. On December 10, 1981, while I was engaged in the same
expressive conduct described in paragraphs 1 and 2 (supra), I was
taken into custody by Officer Pamela (now Rose-Hay) Jackson and
driven by officer Jacqueline Anderson, in a Park Police cruiser, to
the U.S. Park Police, District One sub-station, at 1100 Ohio Drive
4. After being held for some time at the sub-station, I was
taken out of the sub-station and driven, by officers Anderson and
Jackson, in a Park Police transport vehicle, to, as best I was able
to ascertain, the intersection of 30th and Southern Streets, S.E.
At that location, and in the very early morning hours, the officers
stopped the vehicle, opened the door to the chamber in which I had
been locked, and told me to get out.
4. Initially I refused to get out of the vehicle. I
observed to the officers that this was not the area in which I had
been taken into custody, and that I had no desire to be in the area
to which they had brought me. I demanded that the officers return
me to Lafayette Park.
5. Officer Anderson told me that I couldn't return to that
location because "the president and Mrs. Reagan live there." The
officer again ordered me to leave the transport vehicle.
6. I again refused, demanding that I be taken to the N.W.
section of the city.
7. Officer Anderson told me that if I didn't get out of her
transport vehicle she would call for reenforcements, and have me
8. Officer Anderson later told me that she had been given
orders to drive me to a distant location.
Respectfully submitted this _____ day
of _________, 1986.
William Thomas, Plaintiff Pro Se
1440 N Street NW, #4l0, DC 20005
Case Listing --- Proposition One ---- Peace Park