UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.
       Plaintiffs.

         v.                    Civil Action No. 88-3130
                                   Judge Joyce Hens Green
RONALD WILSON REAGAN, et al.
       Defendants.

PLAINTIFFS' COMPLAINT IN SUPPORT OF THEIR
MOTION FOR TEMPORARY RESTRAINING ORDER

FACTS

1. on or about June 13, 1990, U.S. Park Police officers, acting in pre-arranged concert, seized two flags used by plaintiff Picciotto, without probable cause.

2. Seizure of those flags has hampered the exercise of plaintiff's First Amendment rights.

3. The Park Police still retain possession of those flags.

ALLEGATIONS

ONE

Seizure of the flags deprived plaintiff of full exercise of her First Amendment rights.

TWO

Seizure of the flags deprived plaintiff of possession of her property, in violation of the Fourth Amendment.

Respectfully submitted,

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

/s/ W. Thomas
William Thomas
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757

/s/ Ellen Thomas
Ellen Thomas
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005
202-462-0757

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.
       Plaintiffs.

         v.                            Civil Action No. 88-3130
                                         Judge Joyce Hens Green
RONALD WILSON REAGAN, et al.
       Defendants.

CERTIFICATE OF SERVICE

I William Thomas, hereby state that, on this 18th day of September, 1990 I caused a copy of the foregoing Motion for a Temporary Restraining Order, and Declaration of Concepcion Picciotto in Support Thereof, to be hand delivered to the office of Assistant U.S. Attorney Michael Martinez, at Judiciary Square, 555 4th Street, N.W., Washington, D.C. 20001.

William Thomas

PROPOSED ORDER

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.
Plaintiffs.

         v.                              Civil Action No. 88-3130
                                         Judge Joyce Hens Green
RONALD WILSON REAGAN, et al.
       Defendants.

TEMPROARY RESTRAINING ORDER

Upon consideration of plaintiffs' Motion For Preliminary Injunction, defendants' opposition thereto, and the entire record of this case, it is, this day of September, 1990 hereby ORDERED that:

pending resolution of plaintiffs' claims regarding defendants are temporarily restrained from seizing plaintiff Picciotto's two flags.

UNITED STATES DISTRICT COURT JUDGE

COPIES OF THIS ORDER SHOULD BE ADDRESSED TO:

Michael Martinez AUSA
Judiciary Square 555 4th Street N.W.,
Washington, D.C. 20001