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
April 15, 1987
I, Robert Dorrough, declare under penalty of perjury that the
following is accurate and correct to the best of my knowledge:
1. At or about 10:00 AM on April 15, 1987 I observed Richard
Robbins, NPS Solicitor's Office, U.S. Park Police Lt. Hall, Sgt.
Malhoyt, officers Burnette, Dause, and others converging just east
of the center of Lafayette Park, on the south side.
2. After informing William Thomas of their presence, I had
someone else watch my own signs, and went to Concepcion Picciotto's
demonstration site to observe, and to record the conversations to
the best of my ability.
3. Richard Robbins walked up to Concepcion and began to tell
her she had too much property.
4. "What are you talking about?" Concepcion asked. "I only
have what you have already said I could have in your letter."
5. "Well, Connie," Mr. Robbins replied. "that plastic tarp
has to go, and you can only have a small amount of literature.
What's under there?" he continued, referring to the plastic tarp.
6. "Literature," Concepcion answered, and began to pull out
copies of her literature. "The people in the buses come through
and take all of what I have laid out. I am here round the clock.
What should I do?" she asked.
7. "You get rid of the tarp and the literature, or we will
get rid of it." Richard Robbins seemed angry, as he ceased
conversing with Concepcion abruptly.
8. Then Mr. Robbins, surrounded by police officals,
approached Sunrise's demonstration. I followed and sat observing.
9. Robbins instructed Lt. Hall that these people will have to
be woken up.
10. Lt. Hall kicked the blanket that Sunrise was under, and
the foot of a person known to me as "Mike." Lt. Hall asked whether
anyone was under "that tarp," and Sunrise said "No."
11. "You can't have these blankets. That tarp has to go.
You have to get rid of this luggage, and extra clothing," Mr.
Robbins instructed Sunrise.
12. "No," Sunrise responded. "The regulations say that I
cannot store these things. I am using everything here. It doesn't
say that I cna`t have these things; just that I can't store them."
13. "You can't have them," Mr. Robbins reiterated.
14. "Okay, fine," Sunrise said. "If you want them, here
take them. They're not even mine. You want them, you take them."
He started placing the blankets on the sidewalk away from his
signs. Robbins walked away, accompanied by Lt. Hall and some other
officials, but officers Dause and Burnette, who was taking pictures
with a 35 mm camera, remained.
15. I followed Robbins and Hall. They approached my
demonstration site. "Listen," Mr. Robbins started by telling me,
"you're not allowed to have sleeping bags or blankets, and you can
only have enough literature for one day. You can't have this
living stuff here. You have to get rid of this plastic tarp."
16. "Most of this stuff isn't mine, and I've asked the owners
not to put it on or near my signs. As far as my sleeping bag and
plastic is concerned we may have to get a Federal judge to stay out
here for twenty-four hours to decide what's necessary to maintain
17. "All right, Mr. Dorrough," Mr. Robbins replied. He then
walked over to the Thomas' demonstration site. I asked someone to
stay within three feet so that I could closely follow the
conversation and take notes.
18. "Mr.Thomas, we're here to get everybody to reduce the
amount of property here. What's in there?" Mr. Robbins asked,
indicating a milk crate.
19. "Literature," Thomas replied.
20. "Well, Mr. Thomas, we're here to tell you to reduce
21. "Could you be more specific?" Thomas asked.
22. "Your literature needs to be reduced to one day's supply.
What's in that backpack? You're not allowed to have luggage."
23. "I keep legal papers in my backpack. I carry it with me
everywhere I go. When I leave, it goes with me."
24. "Well, what we're looking at is literature." Mr. Robbins
25. "There are several copies of many different pieces of
literature that we pass out to interested persons. I sent a
letter to Sandra Alley about the amount of literature necessary,
and blankets and so forth," Thomas said.
26. "We're not going to permit blankets, and your literature
seems excessive to me. What's in that brown bag?"
27. Thomas took the bag and opened it for Mr. Robbins to see.
"Various things which Ellen is working on, and a roll of
ContactPaper which we us to protect the literature we put on the
28. "Well, you'll have to store it somewhere else," Robbins
said. "What's in that big case?"
29. "I wouldn't call this a big case." Thomas said openning
the container, which measured approximately 4" x 6" x 3'. "Pens,
magic markers, a stapler, tape. Things which we use every day in
the course of our demonstration."
30. "That's more pens than you can reasonably use in one
31. "Not really," Thomas explained. "We are taking
signatures on a petition. We have more than one copy of the
petition (Thomas displayed several copies to Mr. Robbins), and when
there are groups we circulate several at the same time. We also
supply pens to the signers. It's tough to keep track of all the
pens. Folks don't always have a good memory, and we go through a
lot of pens in a day."
32. "You don't need all that for your demonstration. That
would be like saying that it was all right for the Washington Post
to have its presses out here in the Park."
31. Thomas disagreed.
32. "Well, you'll have to store it somewhere else. We
believe it's in excess. What about that blanket? You can't have
33. "I'm sitting on the blanket," Thomas said.
34. "You can't have the blanket."
35. "Do you mean to say that a person is not permitted to sit
on a blanket in the Park?" Thomas asked.
36. "You'll have to get rid of that blanket." Mr. Robbins
appeared to be irate.
37. "If you want the blanket you'll have to take it from me
through force," Thomas said.
38. "Fine," Mr. Robbins answered. "We will." At that point
he walked away from Thomas.
39. During Mr.Robbins' conversation with Thomas I looked up
to see Officer Burnette shove Sunrise three times. I refocused my
attention on the conversation between Mr. Robbins and Thomas. When
I looked again for Sunrise he was handcuffed, and sitting in the
back seat of a police cruiser. I asked Officer Burnette what he
charged Sunrise with.
40. Officer Burnette told me to ask someone else. I then
asked Sgt. Malhoyt, who asked Officer Burnette, and then came back
to me, and informed me that Sunrise had been charged with
41. I witnessed the officials throwing Sunrise's
demonstration materials into the back of an open pickup truck. It
was starting to rain.
Sworn to this ____ day of April, 1987
Case Listing --- Proposition One ---- Peace Park