UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE and PHILIP JOSEPH, et. al., )
                                        )
       Plaintiffs, Pro Se               )
                                        )   CA 88-3130-JHG
          versus                        )
                                        )   Judge Joyce Hens Green
RONALD WILSON REAGAN, et. al.,          )
                                        )
       Defendants                       )
________________________________________)

PLAINTIFFS' MOTION TO PRESENT ARGUMENT ON THE
MOTION FOR A TEMPORARY RESTRAINING ORDER
AT THE HEARING SCHEDULED FOR DECEMBER 2, 1988

On November 23, 1988 plaintiffs filed a Motion for a TRO.

The Court has scheduled a hearing in this matter for December 2, 1988, but, plaintiffs understand, the Court does not plan to hear the TRO at that time.

DISCUSSION

The Complaint in this action is probably expansive, and may even seem somewhat unlikely. However the claim is supported on the record by factual allegations.

At issue here is plaintiffs' contention that they are suffering deprivation of fundamental civil rights guaranteed under the First, Fifth, Ninth and Fourteenth Amendments.

It is thought that a TRO is intended to effect immediate relief, and, no matter how unlikely it may seem, the Complaint should be taken seriously.

Although civil rights may be the bulwark of true civilization, these rights are, nonetheless, extremely fragile.

Without vigilant protection from the Courts civil rights can be easily suffocated by legislatures, executives, or dominant political and community groups.

1

"It is only through free debate and free exchange of ideas that government remains responsive to the will of the people and peaceful change is effected. The right to speak freely and to promote diversity of ideas and programs is therefore one of the chief distinctions that sets us apart from totalitarian regimes.... There is no room under our Constitution for a more restrictive view. For the alternative would lead to standardization of ideas either by legislatures, courts, or dominant political or community groups." Terminiello v. Chicago, 337 U.S. 4, 5 (1948).

CONCLUSION

WHEREFORE plaintiffs pray the Court to hear representations with respect to their Motion for a Temporary Restraining Order.

Respectfully submitted,

________________________
Scott Galindez
Plaintiff, Pro Se
P.O. Box 27217
Washington, D.C. 20038

____________________________
Concepcion Picciotto,
Plaintiff, Pro Se
Post Office Box 4931
Washington, D.C. 20008

_____________________________

Philip Joseph, Pro Se
P.O. Box 27217
Washington, D.C. 20038

___________________________
Sunrise S. Harmony, Pro Se
P.O. Box 27217
Washington, D.C. 20038

_____________________________
William Thomas, Pro Se
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757

_____________________________
Ellen Thomas, Pro Se
Peace Park Antinuclear Vigil
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757


CERTIFICATE OF SERVICE

I William Thomas, hereby state that, on this ____ day of November, 1988 I caused a copy of the foregoing Plaintiffs' Motion to Present Argument on the Motion for a Temporary Restraining Order at the Hearing Scheduled for December 2, 1988,to be hand-delivered to the Office of U.S. Attorney at Judiciary Square, 555 4th Street N.W., Washington, D.C.

_____________________________
William Thomas