UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM THOMAS, et al
Plaintiff Pro Se
versus CA 84-3552
Judge Louis Oberdorfer
UNITED STATES, et al
Defendants
REQUEST FOR WRITTEN FINDINGS
OF SUFFIENCY OF EVIDENCE AND POINTS OF LAW
ON FEDERAL DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
Plaintiffs incorporate by reference the Trial Brief, List of
Trial Exhibits, Trial Exhibits, and Plaintiffs' Memorandum of Law
in Support of Motions for Declaratory Judgment, Preliminary
Injunction, and Summary Judgment, all filed September 22, 1986;
Statement of Claim, filed April 22, 1986 pursuant to Order of Judge
Oberdorfer; Amended Complaint (Am.Com.), filed October 19, 1985;
and the original Complaint, filed November 21, 1984, and all
pleadings filed in response to the Motions for Summary Judgment of
Defendant Canfield, Defendant Lindsey, and Federal Defendants.
If the Magistrate will view this matter against the background
of the Statement of Claim and the Amended Complaint, plaintiffs
believe that the issues in dispute are readily apparent. Balancing
those two documents against the Original Complaint, plaintiffs
submit, it also becomes clear that the Claim has been consistently
stated and modified (at Government counsel's urging) only to focus
the controversy..
In the event that the Magistrate favors Summary Judgment for
the Federal Defendants, plaintiffs pro se, not entirely satisfied
that their oral presentations of November 14, 1986 covered all of
the issues raised in the pleadings, hereby petition the Magistrate
to address in writing the issues raised in the Trial Brief and the
September 22, 1986 Memorandum of Law, as well as all the pleadings
filed by plaintiffs in direct opposition to the Motions of
defendant Canfield, defendant Lindsey, and the other Federal
defendants.
A concise listing by the Magistrate of perceived factual or
legal shortcomings within plaintiffs' pleadings would greatly
expedite this litigation.
Respectfully submitted this 21st day
of November, 1986.
____________________________________
William Thomas, Plaintiff Pro Se
1440 N Street NW, #410
Washington, DC 20005
(202) 462-3542
______________________________
Ellen Thomas, Plaintiff Pro Se
Peace Park Antinuclear Vigil
P.O. Box 27217, D.C., 20038
(202) 462-3542
Case Listing --- Proposition One ---- Peace Park