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.,          )
________________________________________)

DECLARATION OF WILLIAM THOMAS IN SUPPORT OF
PLAINTIFF'S MOTION TO STRIKE DEFENDANTS' EXHIBIT 4

I, William Thomas, hereby declare under penalty of perjury that the following is accurate and correct to the best of my knowledge and recollection:

1. I was never arrested or convicted for any incident occuring on December 7, 1981 or on May 11, 1983.

2. Those dates are not errors in the sense that the arrests or convictions may have occurred on some other date, rather they ever hapeed.

3. To the very best of my recollection, and after considerable research, I am only able to ascertain a total of ten convictions since I began trying to reason with this nation on June 3, 1981.

4. On September 16, 1982 I had been convicted of "camping" at a bench trial before U.S. Magistrate Arthur Burnett.

5. In an effort to conform my continuous presence to my understanding of the Magistrate's interpretation of the camping regulation I altered my activity in several significant and burdensome respects.

6. From September to November 11, 1982, my actions were perfectly peaceful, harmless, and unobjectionable. Nonetheless I remained a target of constant surveillance, frequent intimidation

1

and threats from officials of the Park Police and Secret Service.

7. I attempted to reason with many of the Park Police officials -- some of whom offered the explanation that they were "only following orders" -- to no avail. The harassment continued with the effect of subjecting me to great emotional stress.

8. The constant harassment, and my sincere belief that I was engaged in a fight "to retain the rights guaranteed by the First Amendment" from being stifled under needless administrative policies, drove me to the extreme, but harmless, extent of climbing a tree on November ll, l982, for the purpose of drawing the administrative regulatory enforcement agents into discourse with the intent of arriving at "a little reason and sanity."

9. To increase the likelihood that my symbolic tree climbing would be literally understood I also produced photocopies of two hastily typewritten flyers (Exhibits C and D, attached hereto) which my friend Concepcion Picciotto, standing at the base of the tree, distributed to police officials and passersby.

10. I also personally explained the purpose of my action to several Park Police officials, including Lt. Bruce Clements.

11. Government officals made absolutely no attempt at reason or logic. Instead, and in great numbers, they took me by force to the jail.

12. Those charges were dismissed the following day.

Under penalty of perjury,
_____________________________
William Thomas
Plaintiff, pro se
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757