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 ELLEN THOMAS
RE MARCH 29, 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 29, 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 approximately 11 PM I was in a prone position at my signs, when a man who was very drunk came over and fell down on top of me.

3. My husband, Thomas, picked the man up and walked him away. When Thomas returned he sat down next to me, and put his arm around me. I put my head on his shoulder. We covered ourselves with a cotton quilt to cut out the chilly night air.

4. Approximately fifteen minutes after that incident U.S. Park Police officer Ferebee approached us and said we werebeing warned that we were in violation of the camping regulation.

5. We both asked on what grounds were we camping.

6. "Lying down on bedding for the purpose of sleeping."

7. Thomas told officer Ferebee that he was sitting up, and that his eyes had been open.

8. "Mrs. Thomas is lying down with her eyes closed," Officer Ferbee said.

9. "So if my wife is lying down with her eyes closed, why are you warning me that I am camping?" Thomas asked.

10. "You're both lying under the same blanket."

11. "But I'm sitting up. And my eyes are open," Thomas repeated.

12. "Mrs. Thomas is warned. She's in violation."

13. "But I wasn`t asleep. You walked up, and I responded immediately." I said.

14. "Maybe you're a light sleeper." Ferbee said. "I don't know whether you were sleeping or not."

15. I swore on my Bible to Officer Ferbee that I was neither sleeping nor camping. I explained that I had been camping in the past, and like to camp, but that I always camp in the woods. I explained that I was demonstrating, and that I had given up living accommodations to demonstrate. I asked officer Ferebee why we was harassing us by warning us we were camping.

16. OfficerFerebee said that he had been given orders by his superiors, but would not be specific. He said that he worked for President Reagan.

17. At approximately 6:00 AM Officer Ferebee stood on the grass to the north of our signs, and discussed the Bible with Thomas and me. In the middle of our conversation Ond officer Doerrler arrived and stood on the grass next to officer Ferebee. After a few minutes the two officers walked away together.

18. Approximately ten minutes later Officer Doerrler came back to our signs, where I was sitting up with my eyes open, talking to Thomas. Doerrler said: "You are being warned you are both in violation of the camping regulation."

19. "On what grounds?" I asked.

20. He made no answer.

21. At 7:00 AM Thomas and I left the signs to be attended by a friend. I returned to the signs around 8:30 and commenced talking to passersby about nuclear weapons. Officer Doerrler was leaning against a park bench about 20 yards from my signs, where he remained, watching the demonstrations carefully.

22. At about 10:00 Doerrler walked up and handed me a "camping" ticket.

23. I demanded to know on what grounds he was giving me the ticket.

24. Officer Doerrler refused to reply, and walked back to his previous post, leaning against a park bench. Again and again I asked him on what grounds he was giving me a "camping" ticket. Again and again he ignored me.

25. I tore up the ticket, and dropped the pieces on the ground beside me to express my disgust with his rude silence.

26. Officer Doerrler walked away, and returned a few minutes later to give me a ticket for littering.

27. Later I went up to the blockhouse and knocked on the door. Officer Doerrler emerged. I asked him what he had against me personally that he refused to answer my perfectly logical question. After some discussion he apologized for having ignored me, and told me, "Look, some people have the mistaken idea that 'sleeping' is 'camping.' That clearly is not the case. You were covered with a blanket. That's why I issued a ticket."

29. The temperature at 6:00 a.m. on March 29 was approximately ______ degrees.

28. Over the past couple of weeks officials of the Park Police have increased the frequency of their disturbing encounters with us. Since March 27, 1987 I have felt physically ill as a direct result of this continuing harassment by the Park Police.

______________________________
Ellen Thomas
1440 N St. NW Apt. 410
Washington, D.C.
20005

Case Listing --- Proposition One ---- Peace Park