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 ELLEN THOMAS
RE MARCH 28, 1987
I, Ellen Thomas, hereby declare under penalty of perjury that
the following is true and correct to the best of my knowledge:
1. On or about March 28, 1987, I was maintaining a
round-the-clock vigil in Lafayette Park across from the White
House, as I have done regularly since April, 1984.
2. At about 6:00 a.m. Thomas and I were at our sign covered
by plastic to protect us from the rain.
3. I heard someone, later identified as U.S. Park Police
officer Dowd, shout at the signs next to ours: "You are being
warned you are in violation of camping. Next time I'll issue a
4. As Officer Dowd walked by I lifted the plastic which
covered Thomas and me. He passed on without saying anything.
5. I heard Officer Dowd shout at the signs on the other
side of us: "You are being warned you are in violation of camping.
Next time I'll issue a citation."
6. At about 7:45 AM Thomas and I were both sitting at our
signs, under the plastic, fully awake and organizing our
literature, when officer Dowd returned. It was raining.
7. "You are being warned you are in violation of camping.
Next time I'll issue a citation," Officer Dowd barked.
8. "This is a warning, not a citation. Because last time you
were awake," Officer Dowd barked, and left.
9. Neither Thomas nor I was "asleep" or "camping" on either
1440 N St. NW Apt. 410
Case Listing --- Proposition One ---- Peace Park