UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.,
             Plaintiffs,

         v.                   Civil Action No. 88-3130 (JHG)

RONALD W. REAGAN, et al.,
             Defendants.

FEDERAL DEFENDANTS' MEMORANDUM TO THE COURT

On behalf on the federal defendants, this memorandum reduces to writing the representations of counsel at the hearing on plaintiffs' application for a temporary restraining order on eptember 12, 1989.

For the period 4:30 p.m. on September 12, 1989 to 4:30 p.m. September 22, 1989, there will be no interference by any United States Park Police personnel or other defendants with communicative activities between plaintiffs (including plaintiff Concepcion Picciotto) and members of the news media and general public in Lafayette Park, Washington, D C

A proposed order containing this representation and denying the application for a temporary restraining order is attached hereto.

Plaintiffs' spokesman William Thomas may contact the following counsel for the federal defendants to request an extension of the effective period of this representation beyond 4:30 p.m. on September 22, 1989:

AUSA John C. Cleary, 272-9206 -- Sept. 12-18, 1989

AUSA Michael L. Martinez, 272-9195 -- Sept. 18-22, 1989

Respectfully submitted,

//s// Jay B. Stephens
Jay B. STEPHENS, D.C. Bar #177840
States Attorney

//s// John D. Bates
JOHN D. BATES, D.C. Bar #934927
Assistant United States Attorney

/s/ Michael L. Martinez
MICHAEL L. MARTINEZ, D.C. Bar #347310
AssitAnt United States Attorney

OF COUNSEL:

Richard Robbins
Randolph Myers
Office of the Solicitor
Department of the Interior

JOHN C . CLEARY, D.C. Bar #406339
Assistant United States Attorney

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 12 th day of September, 1989 I served one copy of the foregoing Federal Defendants' Memorandum the Court, via first class U.S. mail, postage prepaid, on,

William Thomas
1440 N Street, N.W., Apt. 410
Washington, D.C. 20038

Concepcion Picciotto
P. O. Box 3942
Washington, D.C. 20008

/s/ John C. Cleary
JOHN C CLEARY, D.C. Bar #406339
Assistant United States Attorney
Judiciary Center
555 Fourth Street, N.W.
4th Floor - Room 4114
Washington, D.C. 20001
(202) 272-9206

_____________________________

1/ Service of a second copy of this document by hand delivery to William Thomas has been arranged for 9:00 a.m. on September 13, 1989 at 555 Fourth Street, N.W. Washington, D.C. 20001.

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.,
             Plaintiffs,

         v.                   Civil Action No. 88-3130 (JHG)

RONALD W. REAGAN, et al.,
             Defendants.

ORDER

UPON CONSIDERATION of plaintiffs' application for a temporary restraining order, the declarations of Concepcion Picciotto and Joseph Vigorito in support thereof, the representations of counsel for the federal defendants at the hearing thereon and the entire record herein, and

UPON CONSIDERATION of the representation of counsel for the federal defendants that, for the period 4:30 p.m. on September 12, 1989 to 4:30 p.m. September 22, 1989, there will be no interference by any United States Park Police personnel or other defendants with communicative activities between plaintiffs (including plaintiff Concepcion Picciotto) and members of the news media and general public in Lafayette Park, Washington, D.C., and

IT APPEARING to the Court that this representation affords plaintiffs the relief sought in their application and that the representation meets with plaintiffs' approval, through their spokesman William Thomas, it is by the Court this day of 1989 hereby

ORDERED that the representation of counsel for the federal defendants is accepted by the Court, and it is

FURTHER ORDERED that plaintiffs' application for a temporary restraining order should be and hereby is denied as moot.

UNITED STATES DISTRICT JUDGE

William Thomas
1440 N Street, N.W., Apt. 410
Washington, D.C. 20038

Concepcion Picciotto
P.O. Box 3942
Washington, D.C. 20008

Michael L. Martinez
John C. Cleary
Assistant United States Attorneys
555 Fourth Street, N.W.
Fourth Floor - Room 4114
Washington, D.C. 20001