THOMAS v. REAGAN

USDC Cr. No. 84-3552

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

SUPPLEMENTAL PLEADING TO
MOTION FOR JOINDER OF CLAIMS AGAINST LT. HUGH IRWIN,
FILED NOVMEBER 20, 1986

INTRODUCTION

On November, 20, 1986 Thomas filed a Motion for Joinder of Claims Against Lt. Hugh Irwin. That document is hereby incorporated by reference, and plaintiff William Thomas further states:

FACTS

1. On or about November 19, 1986 a Judicial Summons was issued against plaintiff by the Superior Court of the District of Columbia.

2. That Summons was apparently issued upon a Complaint sworn to by United States Park Police officer Kathy Lanata.

3. That Summons was apparently issued with the knowledge of Lt. Irwin.

4. There never existed any basis in fact for the Complaint upon which that Summons was issued. (See Declaration of Dr. James L. Evans re November 10, 1986, attachment A hereto.)

5. On November 26, 1986 plaintiff responded to the D.C. Superior Court, where he was informed that the charge had been transferred to the Federal District Court.

6. Subsequently plaintiff responded to the Federal District Court, where he was informed by Magistrate Dwyer that the charges had been dropped.

7. Plaintiff's entire day was wasted.

ALLEGATIONS

Plaintiff suffered anxiety, inconvenience, loss of time, and interference with his communicative activities as a direct result of the issuance of the Judicial Summons against him.

Plaintiff alleges that the charge of assault was false.

Plaintiff alleges that the issuance of the Judicial Summons was a malicious abuse of process.

RELIEF SOUGHT

Plaintiff hereby moves this Court to join Officer Lanata as a defendant in this case for such financial relief as the Court might deem sufficient to discourage her from bringing false charges, and/or maliciously abusing process in violation of 42 USC 1983, to the detriment of plaintiff or others in the future.

Further plaintiff moves to have a claim of malicious abuse of process brought against Lt. Irwin in violation of 42 USC 1983, 1985, and 1986, and for the Court to order such financial recom- pense as might be likely to cause Lt. Irwin to refrain from engaging in "totalitarian police state tactics" with the intent or effect of "stifling individual freedom and personal excellence." (See Complaint, filed November 21, 1984, pg. 111.)

Respectfully submitted this 5th day of December, 1986,

____________________________________
William Thomas, Plaintiff Pro Se
1440 N Street NW, #410, DC 20005
(202) 462-3542


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