Concepcion Picciotto, ) Ellen Thomas, ) Robert Dorrough, and ) C.A. No. __________________ William Thomas, Et. Al. ) Judge______________________ Plaintiffs pro se ) ) v. ) ) Donald Hodel, ) James L. McDaniel, ) the U.S. Park Police, and ) the U.S. Secret Service, ) Defendants. )
I, Ellen Thomas, hereby declare under penalty of perjury that the following is true an correct to the best of my knowledge and understanding:
1. I have regularly maintained a continuous presence in the southern portion of Lafayette Park since April, 1984, for the purpose of communicating the urgency of the global elimination of nuclear weapons.
2. During the course of my continuous presence I have been present on the occasions of scores of bisits to the White House by various Heads of State.
3. I never threatened the security of any person or impeded the passage of any person.
4. I have never before been excluded from the "route of access" of any "visiting Head of State," including passage by President Reagan.
5. I have no intention of threatening the secutiry of Mr. Gorbachev, or to impede his passage.