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
I, Ellen Thomas, plaintiff in the above entitled action,
hereby incorporate by reference all declarations previously made by
me in this matter, and further declare under penalty of perjury
that the following is true and correct to the best to my knowledge:
1. During the course of my communicative activities in
Lafayette Park I have constantly in my possession:
C. petition blanks,
D.two plastic crates to contain the aforesaid
literature, books, and petition blanks.
E. a sheet of polyurathene plastic,
F. one blanket and cushion to sit on (I suffer from
G. a broom,
H. a waterproof case (approximately 2' x 4" x 6")
containing pencils, pens, and other stationery,
I. Two 4' x 4' signs,
J. A puppet.
2. I carry with me at all times a backpack and/or satchel,
containing papers. I use a bicycle for transportation to and from
3. Usually I have a jacket, cape, or poncho, depending on the
weather. Occasionally I take it off. When I'm not going to need
it during a 24-hour period I store it at 1440 N Street NW.
4. At night during cold weather I most often use a "sleeping
bag" to keep warm. If it is very cold I use an extra blanket. In
summer I usually use only one blanket to keep out the night chill.
Those articles are always taken out of the park each morning. They
are not brought into the park until they are put into use.
5. Before coming to the Park to engage in this expressive
activity I had always been accustomed to eight hours of
6. With the exception of several occasions on which I was out
of the Park I do not think I have had one eight hour period of
uninterrupted sleep since April 13, 1984.
7. Any rest which I may get during the course of my
expressive activities comes in the form of deep meditation or light
"cat-naps," frequently interrupted by passing citizens, sirens,
traffic, weather, and police.
8. I am immediately responsive to a voice, car door slamming,
or police radio.
9. I never use shelters in the park.
10. I never conduct any cooking activities or the preparation
of food in the park.
11. I never break ground in the park.
12. I never make any fires in the park.
13. I never store personal property in the park.
14. I never have any privacy in the park.
15. I never bathe or do laundry in the park.
16. I do not have sexual relations in the park.
17. I do have property stored at 1440 N St NW.
18. My laundry is done at 1440 N St NW.
19. I bathe at 1440 N St NW.
20. I have a telephone at 1440 N St NW.
21. I receive mail at 1440 N St NW.
22. I rest and seek privacy at 1440 N St. NW.
23. I often cook food at 1440 N St. NW.
24. No food that I eat is prepared in the Park.
25. I leave Lafayette Park totype, lobby, etc.
26. Lafayette Park is where I work for global nuclear disarmament and, since September 23, 1986, to save the life of Charles
Hyder, fasting Ph.D.
27. I have conversations with people on the issues which I
promote at all hours of the day and night. Many of my most
successful conversations have occurred during the early morning
hoursafter a passerby has spoken to me when my eyes were closed.
28. I believe that even on occasions when a passerby or a
police officer might have passed without speaking, my constant
presence is likely to express my commitment, lend credibility to my
sincerity, and symbolize my message on various levels.
29. Although my signs do help convey to passersby why I'm
maintaining a vigil in Lafayette Park, I believe there is no one
who can speak for me when someone chooses to ask questions.
Respectfully submitted this _____ day
of April, 1987.
1440 N Street NW, #410, DC 20005
Case Listing --- Proposition One ---- Peace Park