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, William 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 maintained a continuous presence on the White House sidewalk and in the southern portion of Lafayette Park since June, 1981, 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 will not threaten 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 will not threaten the secutiry of Mr. Gorbachev, or to impede his passage.
6. At least three days prior to December 5, 11987, when Park Ranger James Banton elivered the Mr. McDaniel's Notice To The
Public (Pl's Ex. 1), Park Service maintenance workers began the erection of barricades along the borders of the shaded areas of the map that accompanying Notice To The Public. Id. page 2.
December 7, 1987