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 ROBERT DORROUGH RE
MARCH 20, 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 9:00 a.m. on March 20, 1987, while seated by
my demonstration signs, I observed U.S. Park Police Lt. Hugh Irwin
taking pictures of demonstration signs on the south side of
2. At about 9:05 a.m. I left the area to get some material
which we had planned to use to fabricate a speaker's platform.
3. At about 9:15 I returned with three pieces of 1 x 6
boards, and a bag of tools. I set those materials down next to
Ellen Thomas, and went over to the center of the park to set up the
stage and public address system.
4. At about 9:20 a.m. I saw officer Hewick making off with
the 1 x 6 boards which I had left next to Ellen Thomas, and was
intending to use to mount the speakers for the permitted
5. I left the stage at the center of the park and ran up to
officer Hewick. I asked him what was happening. He told me to
talk to Lt. Irwin.
6. I went over to where I had left my tools and material.
Sgt. Moyer had my tools and was leaving in the direction of his
vehicle. I told him that the tool bag was mine and that I would
assume control. He and Lt. Irwin said it was being confiscated as
abandoned property. I continued to ask for the return of my
property as Lt. Irwin returned to his car.
7. At about 9:30 a.m. both William Thomas and myself were
trying to reason with Lt. Irwin, explaining that we had a permit
for a speaker's platform, when there was a disturbance at my signs.
8. Officer Hewick ran down the sidewalk to my demonstration
site where I witnessed Sgt. Moyer striking and holding Scott
Galindez, who had been watching my site. When officer Hewick
applied his additional force, Sgt. Moyer slapped the handcuffs on
Scott, and took him away, confiscating two smaller hand-held signs.
9. As a result of the actions of Lt. Irwin and his officers
we were unable to construct the speaker's platform, and unable to
conduct the demonstration as planned, and permitted.
10. At about 3:30 p.m. I observed Edwin Motley III parked in
the area of the signs in a no parking, stopping or standing zone.
Lt. Irwin drove up behind him, asked for registration and license,
wrote him a ticket and told him to drive away. Mr. Motley drove a
few feet before Lt. Irwin stopped him and had officer Ward arrest
him for driving with an expired license.
11. At about 5:30 Edwin Motley returned to the Park on foot.
Scott Galindez who had been arrested approximately six hours
earlier was still no where in sight. Mr. Galindez did not return
until after 7:30 p.m.
Sworn to this ____ day of March, 1987
Case Listing --- Proposition One ---- Peace Park