William Thomas
1440 N Street NW, Apt.#410,
Washington, DC 20005

April 12, 1987

Linda S. Chapman
Assistant United States
Attorney
555 4th Street" N.W.
Room 5915
Washington, D.C. 20001

RE: USA v. Galindez C.R. No. 87-60,
USA v. Semple C.R. No. 87-61,
USA v. Thomas C.R. No. 87-62,
USA v. Joseph C.R. No. 87-63.
USA v. Thomas C.R. No. 87-64,

Dear Ms. Chapman:

In compliance with Local Rule 2-5, and for the sake of clarity, we are writing to obtain discovery in the above captioned case. This discovery request seeks the following specific Brady material (see Brady v. Maryland).

All documents within the custody, possession or control of the U.S. Secret Service, DOT, the U.S. Park Police, Justice Department, and the White House, including the President, which relate to:

A. To any and all defendants, ''street people" or similar groups and/or the desire to diminish their presence in the area of the White House;

B. The desire to restrict the degree of First Amendment activity within the area of the White House;

C. The promulgation of regulation the object of which is to affect the conduct of communicative activity on the grounds or in the area of the White House and/or Lafayette Park.

D. Any and all Case/Incident, Occasion Reports, arrest reports, or notes of observations concerning this defendant, Ellen Thomas, Robert Dorrough, Scott M. Galindez, Stephen Semple, Philip Joseph, Robin White, Andrew ("Andhi") Hammerman, and Dr. James L. Evans, by officers of the United States Park Police, officers of the United States Secret Service, or by any other official of the United States Government or of the District of Columbia made concerning observations conducted since September 1985.

E. Any and all communications from the Executive Office of the President, or any other federal agency, respecting the enforcement of 36 C.F.R. 7.96 (i)(1986) or under its former designation of 36 C.F.R. 50.27(a) in Lafayette Park. The names of all persons arrested for violating 36 C.F.R. 7.96 (i)(1986) and under its former designation of 36 C.F.R. 50.27(a) since September 1984, the dates of those arrests, and the disposition of the charges in each case.

F. The names of all persons observed by the United States Park Police officers sleeping in Lafayette Park or in any other park within the "Memorial Core" area.

G. The substance of any oral, written, or video taped instructions communicated by any other means to the officers responsible for the enforcement of the "camping" regulation within the "Memorial Core" area.

H. Any and all communication made by any employee or agent of the U.S. Secret Service, DOI, National Park Service, the U.S. Park Police, Justice Department, and the White House, including the President, to any and all public media, including radio, television, and news publications, and which relate to: any and all, confessed desires, and/or purported necessities to promulgate regulations which would have the effect or propensity to restrict communicative activity undertaken by individuals or groups under twenty-five in the area of the White House, Lafayette Park, or within the "Memorial Core" area.

I. Any and all communications by any employee or agent of the U.S. Secret Service, DOI, National Park Service the U.S. Park Police, Justice Department, and the white House, including the President, to any and all public media, including radio, television, news, and Government publications, which relate specifically to any or all named defendants, or specific communicative activities which any or all defendants may have been involved in the area of the White House, Lafayette Park, or any "Memorial Core" area between June, 1981, up to and including the present date.

J. Any and all communications by any employee or agent of the U.S. Secret Service, DOI National Park Service the U.S. Park Police, Justice Department, and the White House, including the President, to any and all private individuals, groups or members of other Government branches, or agencies which relate specifically to any or all named defendants, or "street people," or specific communicative activities which any or all defendants may have been involved in the area of the White House, Lafayette Park, or any "Memorial Core" area between June, 1981, up to and including the present date;

We believe these requests are appropriate and necessary to our defense. We appreciate your cooperation, and will be happy

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to clarify these requests at any time. You may contact us by leaving a message at 462-0757.

Your friend,

//s// w thomas
William Thomas