USDC Cr. No. 84-3552

WILLIAM THOMAS                 
      vs.                                   CA No. 84-3552
                                          Judge Louis Oberdorfer
UNITED STATES OF AMERICA, et. al.          Magistrate Arthur Burnett


I, Concepcion Picciotto, hereby declare under penalty of purjury as follows:

1. I am an adult citizen of the United States, and I reside in the District of Columbia.

2. Since my youth I have been avidly interested in an accurate perception of reality, and have told people what I have believed.

3. Beginning in 1976 I devoted my energies to communicating to people my understanding of personal experiences which had affected the break-up of my marriage, which resulted in my becoming alienated from my family and friends.

4. For several years I traveled around the country in search of someone to understand my difficulties, and assist me in finding "Freedom," and "Justice."

5. During the summer of 1981, while communicating in front of the White House, I noticed that Willaim Thomas was sitting continuously on the sidewalk in front of the White House with signs.

6. I observed that many people stopped to talk with Thomas.

7. It seemed obvious to me that Thomas had an idea which might be very useful to me in furthering the ends of my own pursuits.

8. Therefore I decided to stop moving from place to place in search of the understanding which I sensed would lead to Freedom and Justice, and to concentrate my energies by remaining in one place.

9. From August of 1981 until June 17, 1982 I remained, virtually on a constant basis, on the White House sidewalk. Never, even once, did I leave the signs, which I used as an aid in my communications, unless there was someone there to attend them, and even then my absences were rare, for short duration, and only to preform the essential functions of life.

10. During the period from the summer of 1981, and the summer of 1982 I did accumulate various items. These items were stored by me, as neatly as possible, in plastic bags which I placed behind my signs.

11. In the early morning hours of June 17, 1982 I was warned by officials of the United States Park Police that I was in violation of newly issued regulations concerning camping, and that if I did not remove my property from the area I would be arrested.

12. I did not argue with the police officers, but merely told them that I would not sleep.

13. The police officers replied that that would not be acceptable, and that I would have to remove my property from the area.

14. I began to comply with the oders of the officers, moving my property out of Lafayette Park. As there was quite a bit of property this took some time.

15. During that previous year Thomas and I had become quite good friends, and we had developed a mutual respect.

16. Thomas, who had, as I recall, only a bag of literature, a jacket, and a blanket, refused to move when the police ordered him to do so. As he was my friend I was concerned for his welfare and did not want to see him arrested.

17. As I was going back and forth, removing my things from the park, I would stop and speak to Thomas, who was lying on the sidewalk. My object was to convince him to comply with the police orders so that he would not be arrested.

18. After the police arrested Thomas, they also arrested me, although I had been trying to comply with their directives.

19. The charges against me were eventually dropped, but before that happened, Magistrate released Thomas, and I on the condition that we stay out of Lafayette Park between the hours of 10:00Pm and 8:00.

20. The experience of that arrest was horrifing to me.

21. When we were released from jail I felt as though I was in a state of semi-shock, and did not know exactly what to do. I wanted to return to the activity that I had been pursuing before my arrest, but all of my signs and literature had been confiscated by the police. Additionally I was afraid that if I went back to doing what I had been doing the police would again arrest me.

22. After our release from jail Thomas made two more small signs out of cardboard, and went back to sitting where he had been before.

23. While I tried to decide what I would do next, I sat on the wall of the White House fence, next to Thomas.

24. Prior to that time Thomas had had his demonstration, which dealt with an entirely different topic than my own. He had occupied one area of the sidewalk while I confined myself to another.

25. During the time that I sat on the wall next to Thomas I had the opportunity to listen to the conversations which he had with various passers-by. I also had the opportunity to question him about those discussions, and to come to a better understanding of what he was trying to communicate.

26. It began to appear to me that Thomas and I were both seeking essentially the same things, altnough we were expressing ourselves in diferent ways.

27. While I had been seeking Freedom, and Justice on the personal level, Thomas was talking about the same ideals on a broader, international level. Additionally Thomas was talking about Peace, and I came to believe that Freedom and Justice were not possible without Peace.

28. Thomas and I began to "put our heads together" in an effort to better communicate with the public. We arrived at three basic decisions:

A) To make larger signs, so that the police would not mistake us for "campers,"

B) to make sure we had no property stored, which might allow the police to say we were "campers," and

C) to make some arrangement in order to comply with Magistrate Burnett's order that we be out of the park during certain hours. Although we felt this order was wrong, we hoped at the time that the Magistrate would realize that we were only trying to do what we had a right to do, would come to understand that, and come to his senses. Unfortunately that did not happen.

29. Thomas and I spent several days away from our communication activities on the White House sidewalk for the purpose of making twenty-five signs, and one cross. Each of the signs was painted on a 4 foot by eight foot piece of 1/4 inch plywood, and the cross was made of 2x10 lumber approximately eight feet high, with a cross piece of approximately five feet.

30. To facilitate our demonstration within the Magistrate's order, and our idea for more and larger signs, Thomas constructed a cart which measured 18 inches, by 40 inches by 40 inches. This cart served a dual purpose of protecting our literature on writting materials from the elements, and as transportation to move our signs into and out of the park.

31. After Thomas was convicted of "camping" but Magistrate Burnett in September of 1982, he stopped eating all solid foods. He also made a sign which explained that the reason he was on that diet was to enable him to remain, constantly, on the White House sidewalk without being arrested for "camping."

32. At that time Thomas and I re-instated our round-the-clock presence on the sidewalk. However the situation which existed between the summer of 1981 and the summer of 1982, and the situation which existed between the summer of 1982 and the fall and winter of that same year were different in at least two major respects:

A) There was no storage of property, and

B) the "street people" who used to sleep on the sidewalk during 1981, no longer slept there.

33. Despite the facts that Thomas and I did not store property, and that Thomas was on a fast, we were regularly harassed by police officers, usually for "sleeping," and regardless of whether we were sleeping or not.

34. In December of 1982 Thomas and I were threatened by Park Police sargent Thomas Bradley who said, "If you so much as blink, I'll arrest you for camping."

35. On December 6, 1982, we were arrested by sargent Bradley, or officers under his command. Neither Thomas nor I was sleeping at that time. We were talking to one another about the movements of the police because of the threat sargent Bradley had made several nights earlier.

36. At the trial sargent Bradley lied, or gave erroneous information about the situation which existed that night, and that testimony was what caused our conviction. That was the single occasion on which I have been convicted of "camping."

37. On March 11, 1982 Park Police Lt. Merillat, and Assistant Solicitor Patricia Bangert told me that unless I moved two large signs on frames (which Thomas and I had added to our collection of 4 foot x 8 foot signs), and our other signs from the White House sidewalk, I would be arrested. I complied with Lt. Merillat's order

Respectfully submitted this _____ day of _________, 1986.

Concepcion Picciotto, Plaintiff Pro Se
P.O. Box __________ Washington, DC 20005

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