Thomas
Peace Park Anti-nuclear Vigil
P.O. Box 27217
Washington, D.C. 20038

September 26, 1989

Dear Mr. Martinez:

We would appreciate it if you would make available to us the following materials as discovery in Huddle v. Reagan, USDC 88-3130.

1) all intra-departmental and inter-agency documents which have been generated since June 3, 1981 within the possession, custody or control of the Secret Service, Department of Interior, National Park Service, U.S. Park Police, the White House, White House Counsel, Office of Management and Budget, and the District of Columbia Metropolitan Police, which relate to the presence and /or activities of any or all plaintiffs and/or the White House Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil,

2) all intra-departmental and inter-agency documents which have been generated since June 3, 1981 within the possession, custody or control of the Secret Service, Department of Interior, National Park Service, U.S. Park Police, the White House, White House Counsel, Office of Management and Budget, and the District of Columbia Metropolitan Police, which relate to the enactment of any statutes or regulations (including, but not limited to 36 CFR Sections 7.96 (i)(1), 7.96 (g)(5)(viii)(A)(2), 7.96 (g)(5)(ix)(A)(2), 7.96 (g)(5)(x)(A)(3), 7.96 (g)(5)(x)(A)(4), 7.96 (g)(5)(x)(B)(2), 7.96 (g)(5)(xii), 7.96 (g)(5)(xiii), including, as applicable to each regulation, as it was formerly codified under 36 CFR Sections 50.27 36 CFR 50.19(e)(9)(10), and 36 CFR 50.19(e)(11)(12), which have had, or which will have, the effect of or removing, curtailing, or diminishing the presence and/or activities of any or all plaintiffs and/or the White House Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil, in Lafayette Park or the White House sidewalk,

3) all incident and arrest reports which have been generated since July, 1986 within the possession, custody or control of the Secret Service, Department of Interior, National Park Service, U.S. Park Police, the White House, White House Counsel, Office of Management and Budget, and the District of Columbia Metropolitan Police, relating to any or all plaintiffs and/or the White House Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil, or their activities in Lafayette Park or the White House sidewalk,

4) all photographs, video and audio tapes which have been generated since July, 1986 within the posses-sion, custody or control of the Secret Service, Department of Interior, National Park Service, U.S. Park Police, the White House, White House Counsel, Office of Management and Budget, and the District of Columbia Metropolitan Police, relating to any or all plaintiffs and/or the White House Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil, or their activities in Lafayette Park or the White House sidewalk, and specifically:

a) All Uinted States Park Police memoranda, regulations, or directives respecting the enforcement of 36 CFR Sections 7.96 (I)(1), 36 CFR 7.96(e)(9)(10), and 36 CFR 7.96(e)(11)(12), including, as applicable to each regulation, as it was formerly codified under 36 CFR Sections 50.27 and 50.19,

b) the name of any Park Police Officer involved in any arrest under the "camping" regulation,

c) the substance of oral instructions, if any, given to any Park Police Officer who was involved in any arrest under the "camping" regulation,

d) the names of all persons observed by U.S. Park Police officers to be sleeping in Lafayette Park, and in any other park within the "Memorial Core" area since July, 1986,

e) the names of all persons arrested for allegedly violating the "camping" regulation since September 25, 1984, the dates of those arrests, and the disposition of the charges in each case,

f) any and all notes of observations, including case incident reports, criminal reports, or any other writings concerning any or all plaintiffs and/or the White House Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil, or their activities in Lafayette Park or the White House sidewalk generated by officers of the United States Park Police, Officers of the United States Secret Service, Officers of the Metropolitan Police, or by any other official of the United States government or of the government of the District of Columbia since July 1986.

5) plaintiffs ask for leave of Court to supplement these requests as plaintiffs' investigation may reveal further evidence of wrongful conduct, particularly of motivation contrary to the intent and provisions of 5 U.S.C. 552 on the part of the Secret Service, the Park Police, the District of Columbia Metropolitan Police, Department of Interior, National Park Service, White House, White House Counsel, Office of Management and Budget, or other members of the executive branch whose influence impacts on the promulgation and enforcement of regulations relating to the activities of any or all plaintiffs and/or the White House Anti-nuclear Vigil and/or the Peace Park Anti-nuclear Vigil, or their activities in Lafayette Park or the White House sidewalk.

Sincerely,

William Thomas