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 23, 1987
I, Robert Dorrough, declare under penalty of perjury that the
following is accurate and correct to the best of my knowledge:
1. On or about March 23, 1987, at about 6:00 am I was rousted
by U.S. Park Police officer Hewick. "Wake up. Get up, Robert."
2. I observed him pulling and prodding two individuals,
Scott Galindez, and Kayleen Purdy, who were reposing beside my
signs. "Who are you." He asked. then he recognized Scott
Galindez and began calling him by name.
3. Officer Hewick then walked to the center of the Park where
Concepcion Picciotto has her display. I observed him rigging up a
piece of blue plastic which Concepcion uses to cover
her literature. I moved down to where Concepcion was in order to
observe closer. when I arrived officer Hewick was engaged in a
search of Concepcion's things.
4. Next he visited the other sites and began to search
through everyone else's effects.
5. While officer Hewick was rooting around the demonstration
of Sunrise I approached him and said: "Excuse me sir, but what is
your probable cause?"
6. "I dont't need one." He said.
7. "I beg to differ, sir, but yes you do."
8. "That's where you're wrong." Officer Hewick insisted.
"You're out here in the open. You have no expectation of privacy.
I need no probable cause. If you had any understanding of the law
you'd know that."
9. I walked back to my demonstration site, followed by
officer Hewick, who quickly gave my material the once over.
"You're alright." He said.
10. Kayleen Purdy had already departed. Then officer Hewick
addressed Scott Galindez. "Scott are you part of this
11. "Yes." Scott replied.
12. "Good, I'm confiscating this." Officer Hewick replied,
and grabbed a 24 inch by 18 inch sign which Scott had near his
13. Scott pleaded with him to return the sign, but to no
14. Scott told me that it was 6:13 am.
Sworn to this ____ day of March, 1987
Case Listing --- Proposition One ---- Peace Park