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
DECLARATION OF CONNECPICION PICCIOTTO
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
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
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
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
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
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
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
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
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
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.
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.
Respectfully submitted this _____ day
of _________, 1986.
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.
Concepcion Picciotto, Plaintiff Pro Se
P.O. Box __________ Washington, DC 20005
Case Listing --- Proposition One ---- Peace Park