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 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
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
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
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
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
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
23. I demanded to know on what grounds he was giving me the
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.
1440 N St. NW Apt. 410
Case Listing --- Proposition One ---- Peace Park