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

PLAINTIFFS' RESPONSE TO THE COURT'S NOTICE TO COUNSEL

On July 28, 1988 this Court entered a Notice To Counsel inviting the parties to "comment() on the question whether this Court may judicially notice the permit material."

The records attached to the Court's Notice To Counsel are certainly germaine to this matter and do merit serious considera- tion, however plaintiffs would strongly object to any presumption that those records are a complete or accurate representation of all "applications and related communications pertaining to demon- stration permits plaintiffs have sought and received from Depart- ment of the Interior officials in reference to plaintiffs' First Amendment activity in Lafayette Park." [1] Notice To Counsel. With all due respect, plaintiffs would comment:

1. various agreements made in the applicatian are unnecessarily restrictive, and needlessly hamper communicative efforts (e.g., not more than 2,500 pieces of literature at any one time, not more than 10 books, 4'x4' foot signs, three foot attendence requirement, restrictions on speaker's platforms and public address systems), and the Court should not assume that

[1 See, e.g., Complaint, filed, November 21, 1984, Exhibits 24, 30, 31, 35.,and paras. 93, 105, 106, 107, 108, and 117, also, Amended Complaint, filed October 19, 1985, paras. 79r 84 and 90. cf., Memorandum Opinion, Report & Recommendation of Magistrate Arthur L. Burnett, filed, January 13, 1987 at pages 13 and 14.]

1

plaintiffs compliance with the provisions of this permit indicate that they believe it is acceptable, necessary, or legal;

2. The Federal Register, March 5, 1988, included in the material supplied by defendants' counsel, is a primary subject of this action. SEE, Amended Complaint, pages 24 - 37, also, Oppo- sition To Federal Defendant's Motion For Judgement On The Admin- istrative Record, filed September 22, 1986;

3. the only reasons plaintiffs applied for this specific permit was to illustrate their civility, and the fact that the activities in which they had been engaged, and for which they had been arrested, were perfectly permissable, and that the defendants had been harassing plaintiffs for engaging in a permissable activity.

(signed) W. Thomas
William Thomas, Plaintiff Pro Se
1440 N Street NW, #410, DC 20005
(202) 462-0757

CERTIFICATE OF SERVICE

I, William Thomas, hereby state that on this 5th day af August, 1988, I senred copies of the foregoing PLAINTIFFS' RESPONSE TO THE COURT'S NOTICE TO COUNSEL by hand at the offices of:

AUSA Michael L. Martinez
Rm. 4822 Judiciary Center
555 4th Street, N.W.
Washington, D.C. 20001

D.C. Corporation Counsel
District Building
Pennsylvania Ave. N.W.
Washington, D.C.

William Thomas,Plaintiff Pro Se

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