USDC Cr. No. 84-3552
THOMAS v. REAGAN
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
DECLARATION OF WILLIAM THOMAS
REGARDING CITATION ISSUED BY OFFICER WARD
DECEMBER 22, 1986
I, William Thomas, plaintiff pro se in the above entitled
action, hereby declare under penalty of perjury that the following
is true and correct to the best of my knowledge:
1. On December 21, 1986 I arrived in Lafayette Park at
approximately 2330 hrs.
2. According to the Washington Post, December 22, 1986, the
temperature at that time was 32 degrees Farhenheit check sp.
3. At approximately 2345hrs I lay down on the sidewalk in a
sleeping bag, next to my wife, Ellen Thomas, who was in another
sleeping bag. We spoke for approximately fifteen minutes before I
drifted off into a nap.
4. My nap continued until approximately 0130hrs when my
attention was drawn a Park Police vehicle which, for no reason
discernible to me, had halted next to the curb on the north side of
Pennsylvania Avenue and sounded its siren.
5. At that point I lay on the sidewalk completely awake for
another fourty-five minutes.
6. At approximately 0226hrs my attention was drawn by the
sound of a police radio. Officer Ward appeared from behind one of
my signs, handed me a citation, and said: "Mr. Thomas, your
activities constitute a violation of the camping regulation." At
that time Officer Ward was accompanied by Officer Covington.
7. At approximately 0315hrs, I left the park to urinate, as
is my custom. I returned at approximately 0320 hrs, when I saw
Concepcion Picciotto awake and sitting up. She said "hello" to me.
8. I remained totally awake until approximately 0345hrs,
when I heard the sound of a car door slam. Upon hearing a slight
commotion some distance to the east of where I was lying, I got to
my feet to investigate. I arose in time to see a Park Police
supervisor's car pulling away from the curb. I noticed Concepcion
Picciotto was on her feet.
9. At approximately 0435hrs an individual, who identified
himself as Park Police evidence technician Simonella, photographed
Ellen and I. That individual was in the presence of Officer Ward,
and two Park Police sergeants, whom I am unable to identify at this
Executed December 23, 1986.
William Thomas, Plaintiff Pro Se
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
Case Listing --- Proposition One ---- Peace Park