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
DECLARATION OF ROBERT DORROUGH RE
MARCH 11, 1987
I, Robert Dorrough, declare under penalty of perjury that the
following is accurate and correct to the best of my knowledge:
1. At, or about 11:40 am on March 11, 1987 I observed U.S.
Park Police Lt. Hugh Irwin taking pictures of demonstration signs
used by Ellen and Thomas in the course of certain expressive
activities.
2. At that time Ellen was delivering literature about Charles
Hyder, which I had helped prepare, to various groups and
individuals.
3. Thomas had gone, with Dr. James L. Evans, to 1100 Ohio Dr. for Dr. Evans to obtain a demonstration permit for March 20, 1987.
(SEE Attachment 1.) And I was attending Thomas'' signs in their
absence.
4. I asked Lt. Irwin if the Solicitor's Office of the
Department of Interior had asked him to take the photos.
5. Lt. Irwin responded: "I don't know."
6. Later I made the same inquiry, and Lt. Irwin responded:
"I do not wish to answer a privilege I wish to exercise."
7. At, or about 11:47 I observed Richard Robbins and
Patricia Bangert, of the Solicitor's Office of the Department of
Interior, sitting in a Park Police cruiser talking with Lt. Irwin,
and pointing at the signs. I waved at Mr. Robbins, and he waved
back.
8. At about 12 noon I observed a white unmarked car drive by
the signs with Secretary of the Interior Department, Donald Hodel,
seated in the back.
Sworn to this ____ day of March, 1987
_________________________________
Robert Dorrough
Case Listing --- Proposition One ---- Peace Park