CONCEPCION PICCIOTTO, et. al., Plaintiffs, v. Civil Action No. 87-3290-LFO DONALD MODEL, et. al.,
Initially the defendants provided no legal authority for the contested action of closing a section of Lafayette Park.
After the Government finally referred to purported legal authority (36 CFR 1.5), plaintiffs' research indicated that the Government had clearly failed to fulfill the legal pre-requisites for the implementation of measures to close a public park.
In light of the defendants' tardy identification of legal authority, and plaintiffs pro se ignorance of the related law, plaintiffs now move for leave to file an amended proposed Order both to clarify the legal issues as plaintiffs perceive them, as well as to save the Court's time. Respectfully submitted,
William Thomas 203-012
Occoquan II, Dorm K-II
P.O. Box 85
I, William Thomas, hereby certify that, on this 25th day of
February, 1988, a copy of the foregoing Plaintiffs' Motion For
Leave To File An Amended Proposed Order was served, by first class
U.S. mail, postage pre-paid, upon AUSA Micheal Martinez, Judiciary
Square, 555 4th Street, N.W., Washington, D.C., 20001.