PHILIP JOSEPH, et al., ) ) Plaintiffs pro se, ) ) CA 88-3130 versus ) ) Judge Joyce Hens Green RONALD WILSON REAGAN, et al., ) ) Defendants ) ______________________________________)
INTRODUCTION | |
HISTORY OF LAFAYETTE PARK | Exhibit A |
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A-3 | |
A-4 | |
A-5 | |
A-6 | |
A-7 | |
A-8 | |
A-9 | |
ONGOING SAGA | Exhibit B |
B-1 | |
B-2 | |
B-3 | |
B-4 | |
B-5 | |
B-6 | |
B-7 | |
B-8 | |
B-9 | |
B-10 | |
B-11 | |
B-12 | |
B-13 | |
DEFENDANTS' PROBLEM | Exhibit C |
C-1 | |
C-2 | |
A SOLUTION? | Exhibit D |
D-1 | |
THE CIVILIZED SORT OF WAY | Exhibit E |
E-1 | |
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E-3 | |
E-4 | |
E-5 | |
E-6 | |
E-7 |
FACTS | |
Clarification of Complaint Para | |
1 | Exhibit 1 (A),(B),(C),(D),(E), Secret Service Reports, June 16, 1981. |
2 | Exhibit 2, Roofener arrest report, July 6, 1981. |
3 | Exhibit 3, Magistrate Burnett's Opinion, Thomas v. USA CA 84-3552, filed January 13, 1987. |
4 | Exhibit 4, Secret Service Report, July 6, 1981. |
5 | Exhibit 5, Art Spitzer letter to Thomas, May 10, 1983. |
6 | Exhibit 6, Boston Globe article, August 27, 1981. |
7 | Exhibit 7, Mitch Snyder letter, June 30, 1983. |
8 | Exhibit 8, Manus ("Jack") Fish letter, November 13, 1981. |
9 | Exhibit 9, Federal Register (Fed Reg), Vol. 46, No. 219, November 13, 1981, p. 55959-55961. |
10 | Exhibit 10 (a),(b),(c),(d),(e), various Park Police Case Incident Reports, November 12 to 14, 1981, Nature of Incident: "Demonstration (Vigil)." |
11 | Exhibit 11, ERA v. Watt, USDC CA-83-1243, Richard Robbins testimony, December 6, 1983, Transcript pg. 37-38. |
12 | Exhibit 12, CCNV v. Watt, CA 81-2844, November 24, 1981, transcript pp. 38-39 (pp. 38-39), Judge Barrington Parker. |
13 | Exhibit 13, Lt. J. Schamp, U.S.P.P Case Incident Report, November 26, 1981. |
15 | Exhibit 14, Thomas notice, November 27, 1981. |
16 | Exhibit 15, Affidavit of Larry Tucker, November 2, 1982. |
17 | Exhibit 16-A, Case Incident Report, Officer Moore, December 12, 1981. |
18 | Exhibit 16-B, Testimony Officer Samuel Wolz USA v. Thomas, USDC, 82-0329(M), September 16, 1982, transcript at 88. |
19 | Exhibit 17, Secret Service Report, January 11, 1982. |
20 | Exhibit 18, Thomas' Statement, December 25, 1981. |
21 | Exhibit 19-A, AP wire release December 25, 1981. |
21 | Exhibit 19-B, Washington Post/UPI article December 26, 1981. |
22 | Exhibit 20, Case Incident Report USPP Officer R.F. Perkins, January 5, 1981. |
23 | Exhibit 21, Testimony of Jerry Parr, May 3, 1983, CA-83-1243, ERA v. Watt, transcript p. 35-36. |
24 | Exhibit 22, Deposition of Patricia Bangert, ERA v. Watt, November 21, 1983 at 72-73. |
25 | Exhibit 23, Letter from Manus Fish, April 21, 1982. |
26 | Exhibit 24, Fed. Reg. Vol. 47, No. 108, p. 24304, June 4, 1982, 36 CFR 50-27(a), written by defendant Robbins. |
27 | Exhibit 25, Fish letter, June 4, 1982. |
28 | Exhibit 26, Thomas letter, June 5, 1982. |
29 | Exhibit 27, testimony, Officer Wolz, USA v. Thomas, USDC, Cr 82-0329(M), September 16, 1982, transcript at 122. |
30 | Exhibit 28, USPP Walter Sherba report, June 17, 1982. |
31 | Exhibit 29, testimony, Officer Wolz, USA v. Thomas, USDC, Cr 82-0329(M), September 16, 1982, transcript at 103-104. |
32 | Exhibit 30-A, Declaration of Carol Fennelly, CCNV v. Watt, CA 82-2501, October 3, 1982. |
32 | Exhibit 30-B, Declaration of Barbara Gamarekian, CCNV v. Watt, CA 82-2501, October 1, 1982. |
33 | Exhibit 31, Occasion Report, Officer Ferebee, November 12, 1982. |
34 | Exhibit 32-A Occasion Report, Officer Ferebee, November 13, 1982. |
34 | Exhibit 32-B, Thomas letter November 10, 1982, Statement of Reason. |
35 | Exhibit 33, Robbins testimony, ERA v. Watt, USDC CA 83-1243, December 6, 1983, transcript at 48. |
36 | Exhibit 34, Memo to the Force from J.C. Lindsey, December 6, 1982. |
37 | Exhibit 35, testimony Officer Shea, USA v. Thomas CR 82-358, May 17, 1983, transcript p. 91. |
38 | Exhibit 36, USA v. Thomas CR 83-358, transcript July 5, 1983, p. 4, Judge Bryant. |
38 | Exhibit 37, USA v. Thomas CR 83-056, transcript July 7, 1983, p. 1-13. |
39 | Exhibit 38-A, testimony J.C. Lindsey, U.S. v. Thomas, CR 83-329-M, September 3, 1982. |
39 | Exhibit 38-B, DOI letter to USPP Chief Herring, February 5, 1985. |
40 | Exhibit 39, ERA v. Watt, USDC CA-83-1243, Richard Robbins testimony, December 6, 1983, Transcript p. 6-7. |
41 | Exhibit 40, letter from Douglas Applegate, United States House of Representatives, October 3, 1983, re December 1982 VVAW vigil. |
43 | Exhibit 41, Jerry Parr letter to Richard Robbins, January 10, 1983. |
44 | Exhibit 42, Memo from James G. Watt, January 13, 1983. |
45 | Exhibit 43, Robbins letter to "the Reviewers" dated February 25, 1983. |
46 | Exhibit 44, report by Officer Shea March 3, 1983. |
46 | Exhibit 45, report by Officer Ferebee March 10, 1983. |
47 | Exhibit 46-A, Merillat testimony, USA v. Thomas CR 83-056, May 19, 1983, p. 59. |
47 | Exhibit 46-B, testimony of Lt. Merillat, USA v. Thomas,USDC, CR 83-056, May 19, 1983 at 64. |
48 | Exhibit 47, Declaration of Arthur Spitzer, July 15, 1986. |
49 | Exhibit 48, Robbins testimony ERA v. Watt, December 6, 1983, pages 50, 112. |
50 | Exhibit 49, defendant Canfield's Grand Jury testimony. April 8, 1983, pp. 2-4. |
51 | Exhibit 50, testimony of Lt. Merillat, USA v. Thomas, USDC, CR 83-056, May 19, 1983 at 50. |
52 | Exhibit 51, testimony of Lt. Merillat, USA v. Thomas, USDC, CR 83-056, May 19, 1983 at 51. |
52 | Exhibit 52, Canfield deposition, Thomas v. USA, CA 84-3552, July 10, 1986. |
53 | Exhibit 53, ERA, CA 83-1243, Robbins testimony, May 3, 1983, Trial Transcript, 66-67. |
54 | Exhibit 54, Lt. Treon letter June 7, 1982. |
55 | Exhibit 55, Robbins testimony May 3, 1983, ERA v. Watt, at 51. |
56 | Exhibit 56, testimony of Lt. Merillat, USA v. Thomas, USDC, CR 83-056, May 19, 1983 at 75. |
57 | Exhibit 57, testimony of Lt. Merillat May 19, 1983 USA v. Thomas, USDC CR 83-056, pg. 70, 71. |
58 | Exhibit 58, Robbins Deposition ERA v. Watt, November 21, 1983, p. 13. |
59 | Exhibit 59-A, Affidavit of Concepcion Picciotto, January 17, 1986. |
59 | Exhibit 59-B, testimony of Merillat, CR 83-056, May 19, 1983, at page 73. |
60 | Exhibit 60, Public Defender Service Memorandum, Allie Sheffield to Charles Ogletree, July 26, 1983. |
61 | Exhibit 61-A, James report March 13, 1983. |
61 | Exhibit 61-B, Officer James testimony, May 19, 1983, USA v. Thomas, Cr 83-056, at p. 17. |
62 | Exhibit 62, Minzak arrest report, March 15, 1983 (poor-quality copy provided by federal defendants). |
63 | Exhibit 63, Statement of William Thomas, March 16, 1983. |
64 | Exhibit 64-A, "The President's News," August 22, 1985. |
64 | Exhibit 64-B, New York Times, June 23, 1984. |
64 | Exhibit 64-C, Washington TIMES article by Gene Goltz, 3- 16-83. |
64 | Exhibit64-D, Washington TIMES article, "Defacing the White House: Update," 3/18/83. |
65 | Exhibit 65, Parr letter, undated, initialed by Robbins 3-21-63. |
66 | Exhibit 66, Request for OMB Review, signed March 28, 1983 by defendant Fish. |
67 | Exhibit 67, Jerry Parr letter, April 20, 1983. |
68 | Exhibit 68, Fed. Reg April 22, 1983. |
69 | Exhibit 69, ERA v. Clark, USDC CA 83-1243, Memorandum and Order, J. Bryant, filed April 26, 1984. |
70 | Exhibit 70, Deposition of Patricia Bangert, ERA v. Watt, November 21, 1983 at 63. |
71 | Exhibit 71-A, Officer Woods report, April 27, 1983. |
71 | Exhibit 71-B, photographs of the "crime." |
72 | Exhibit 72, Affidavit of Mary Ann Beall, White House Vigil for the ERA CA 83-1243, executed April 28, 1983. |
73 | Exhibit 73, J.C. Lindsey, Affidavit May 2, 1983. |
74 | Exhibit 74, Jerry Parr testimony, ERA, May 3, 1983, p. 37. |
75 | Exhibit 75, Secret Service report, May 6, 1983. |
76 | Exhibit 76, Fed. Reg Vol 48 No. 95 May 17, 1983, pg. 22284, 22285. |
77 | Exhibit 77, letter dated May 27, 1983 from U.S. Park Police Chief Lynn Herring, emphasis added. |
78 | Exhibit 78, Fed Reg Vol 48 No 118, June 17, 1983. |
80 | Exhibit 79, Robbins deposition ERA v. Clark, CA 83-1243, November 21, 1983, p. 53. |
80 | Exhibit 80-A, letter, March 12, 1982, to the Washington Times, signed Frank J. Miller, copy to defendants' agent Elmer Atkins. |
80 | Exhibit 80-B, letter to the President, signed "A Concerned American, G. T. Finch," dated November 30, 1982. |
81 | Exhibit 81, Vanderstar during Robbins testimony, ERA, May 3, 1983, p. 41. |
82 | Exhibit 82, Lindsey testimony, USA v. Thomas CR 83-186, October 21, 1983 Transcript p. 113. |
83 | Exhibit 83, Park Police report June 17, 1983, reported by Chief Lindsey, and investigated by Officer Hennessey. |
84 | Exhibit 84, William Thomas declaration, USA v. Thomas CR 82-385, July 1, 1983. |
85 | Exhibit 85, testimony, Officer Sherba, USA v. Thomas, USDC, CR 83-243, December 3, 1983, transcript at 73. |
86 | Exhibit 86, 36 CFR 50.19(8)(v). |
87 | Exhibit 87-A, Ellen Thomas Declaration, May 12, 1987. |
87 | Exhibit 87-B, Sunrise Declaration, May 12, 1987. |
87 | Exhibit 87-C, Philip Joseph Declaration, May 12, 1987. |
88 | Exhibit 88-A, Secret Service report, July 22, 1983. |
88 | Exhibit 88-B, Secret Service report, July 23, 1983. |
89 | Exhibit 89-A, U.S Park Police report, Officer Guentz, July 25, 1983. |
89 | Exhibit 89-B, Testimony of Lt. Clipper, USA v. Thomas, CR 83-106, November 14, 1983 transcript p. 35. |
90 | Exhibit 90, Park Police report, Officer Haynes, September 24, 1983. |
91 | Exhibit 91, Testimony, Officer Haynes, USA v. Thomas, 84-255, transcript at 783, September 24, 1984. |
92 | Exhibit 92, USPP report, Haynes, January 31, 1984. |
93 | Exhibit 93-A, "William Thomas Demonstration," U.S. Park Police report, Roofener, May 4, 1984. |
93 | Exhibit 93-B, "William Thomas White House Vigil Society,& Tkach, May 8, 1984. |
93 | Exhibit 93-C, "Demonstration," Roofener Occasion Report, May 6, 1984. |
94 | Exhibit 94, USA v. Dorrough, CR 84-0283M-01, trial transcript July 23, 1984 (pp. 7, 10-12, 14-15, 18), testimony of U.S. Park Police Officer Donald Roofener re May 9, 1984 arrest. |
95 | Exhibit 95, Thomases' permit application, May 29, 1984. |
96 | Exhibit 96-A, National Park Service Permit #84-564, May 30, 1984. |
96 | Exhibit 96-B, diagram of speaker's platform permitted by NPS. |
97 | Exhibit 97, U.S. Park Police report, Officer Manso, May 31, 1984. |
98 | Exhibit 98, Park Police report, Haynes, June 6, 1984. |
99 | Exhibit 99-A, Park Police report, Haynes June 22, 1984. |
99 | Exhibit 99-B, Park Police report, Sgt. Jones, June 18, 1984. |
100 | Exhibit 100, Park Police report, Sgt. Jones, November 8, 1984. |
101 | Exhibit 101-A, GW Hospital Report, Robert Dorrough, June 8, 1984. |
101 | Exhibit 101-B,Declaration of Ellen Thomas, Thomas v. USA, CA 84-3552, filed September 22, 1986. |
101 | Exhibit 101-C, letter from Ellen Thomas to USPP Chief Lynn Herring. |
101 | Exhibit 101-D, letter from Ellen Thomas to Officer Haynes. |
102 | Exhibit 102, Washington Post article, June 7, 1984. |
103 | Exhibit 103, Officer Haynes' testimony, USA v. Thomas 84-255, September 24, 1984, p. 617. |
104 | Exhibit 104, Testimony of Officer Agusiewicz, USA v. Thomas, CR 84-255, September 18, 1984. |
105 | Exhibit 105, U.S. District Court Judge Joyce Hens Green, USA v. Thomas, USDC 84-255, September 25, 1984, Findings of Fact. |
106 | Exhibit 106-A, letter from defendant Lindsey to defendant Robbins, June 14, 1984; compare to Exhibit 106-B, Officer Smallwood report, June 14, 1984. |
107 | Exhibit 107, Officer Haynes report, June 23, 1984. |
108 | Exhibit 108, Officer Haynes report June 24, 1984. |
109 | Exhibit 109, Declaration of Robert Dorrough, filed September 22, 1986. |
110 | Exhibit 110-A, UPI report, June 24, 1984. |
110 | Exhibit 110-B, Washington Post report, June 24, 1984. |
111 | Exhibit 111-A, J. Oberdorfer Order filed July 19, 1984, USDC, USA v. Thomas, CR 83-243. |
111 | Exhibit 111-B, letter from Thomas to Department of Interior, National Park Service, et al, July 21, 1984. |
111 | Exhibit 111-C, Thomas letter to Robbins, September 16, 1985. |
111 | Exhibit 111-D, Thomas Petition to Robert Bedell, Office of Management and Budget (OMB), September 16, 1985. |
111 | Exhibit 111-E, Bedell letter to Thomas (undated). |
111 | Exhibit 111-F, Thomas letter to Robbins, June 3, 1986. |
111 | Exhibit 111-G, Robbins letter to Thomas, July 3, 1986. |
112 | Exhibit 112, List of Violators, 36 CFR 50.27(a), 1983-84. |
113 | Exhibit 113-A, Federal Defendant's Motion for Judgment on the Administrative Record, Thomas v. USA CA 84-3552. |
113 | Exhibit 113-B, Opposition to Federal Defendants' Motion for Judgment on the Administrative Record, ibid., filed September 22, 1986. |
114 | Exhibit 114, D.O.I. Ad Hoc Liaison Committee on President's Park Signs, "Public Expressions," report, September 18, 1984. |
115 | Exhibit 115, Affidavit David Manning filed August 27, 1986. |
116 | Exhibit 116, National Park Service letter, October 5, 1984. |
117 | Exhibit 117, Affidavit of William C. Wardlaw, December 21, 1985. |
118 | Exhibit 118, Thomas Permit, September 18, 1984. |
119 | Exhibit 119, Park Police report, J. Murray, 10-15-84. |
120 | Exhibit 120-A, Park Police report, May 9, 1985, Officer unidentifable by our record. Compare Declaration of Ellen Thomas, Exhibit 100-B. |
120 | Exhibit 120-B, National Park Service Permits, April 12, 1985. |
121 | Exhibit 121, Case Incident Report, Sgt. Moyer, June 8, 1985, 0019 a.m. |
122 | Exhibit 122, Case Incident report, Officer Brown, June 8, 1985, 0745 am. |
123 | Exhibit 123, Case Incident report, Officer Brown, September 29, 1985, re June 8, 1985. |
124 | Exhibit 124, June 3, 1985 Letter from Thomas to Reagan. |
125 | Exhibit 125, June 5, 1985 Letter from the White House to Mitch Snyder. |
126 | Exhibit 126, Robbins letter to Senator Hatfield, March 5, 1985. |
127 | Exhibit 127-A, Case Incident Record, Officer Covington, July 5, 1985. |
127 | Exhibit 127-B, Federal Management Magazine, Vol 6, No 3, 1987 |
127 | Exhibit 127-C, Jay Young, President's Park Legal Defense Fund, undated. |
128 | Exhibit 128, Request for OMB Rulemaking Review, August 7, 1985, signed by Manus J. Fish. |
129 | Exhibit 129, Fed.Reg. Vol. 50 No. 161, Tuesday August 20, 1985, at pages 33571 - 33575. |
130 | Exhibit 130, Park Police report, signed by Officer Lindsey and Sergeant Wilkins, 11-18-85. |
131 | Exhibit 131, 36 CFR 50.19(e)(11)(12), final rule published March 5, 1986, Vol. 51, No. 43 Fed. Reg., pp. 7556 - 7566. |
132 | Exhibit 132, USA v. Joseph, et al, CR 86-061-065, Order, J. Richey, April 23, 1987. |
133 | Exhibits 133-A and 133-B, photographs of Lt. Hugh Irwin choking Thomas, November 11, 1986. |
133 | Exhibit 133-C, Motion for Joinder Against Lt. Irwin, November 21, 1986 |
133 | Exhibit 133-D, Declaration of William Thomas re November 21, 1986 |
134 | Exhibit 134, USA v. Thomas and Thomas, CR 87-231, Trial Transcript, December 14, 15, 1988. |
135 | Exhibit 135-A and 135-B, Orders, USA v. Sunrise (aka Semple), CR 87-3064. |
136 | Exhibit 136, Picciotto et al v. Hodel, DSDC CA 87-3290, Memorandum & Order, J. Oberdorfer, filed December 9, 1987. |
137 | Exhibit 137, United States v. Joseph et al, USDC CR 87-061-065, J. Richey, Trial Transcript, December 15, 1987. |
138 | Exhibit 138,Peace Release, Winter '89. |
139 | Exhibit 139, United States v. Sunrise, USDC CR 88-235, Memorandum J. Oberdorfer, filed December 8, 1988. |
140 | Declaration of Concepcion Picciotto, January 6, 1989. |
141 | Permit Application, March 11, 1987. |