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


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