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' RENEWED MOTION FOR PRELIMINARY INJUNCTION

Pursuant to Rule 65, plaintiffs hereby petition the Court for an Order which would restore the status quo ante bellum as regards freedom of speech and assembly, freedom from unlawful search and seizure, the unenumerated right to remain in a public park, and equal protection within the jurisdiction of the National Capitol Region of the National Park Service by

1. restraining defendants from threatening, harassing, intimidating, arresting, or alleging a violation of the "camping" regulation for merely wrapping oneself against the night air, or falling asleep from physical exhaustion during the protected act of maintaining a continuous presence,

2. to enjoin the seizure of plaintiffs' lawful signs and literature,

3. to enjoin the seizure of property as "abandoned" in any incident where an individual asserts an intention to retain possession of the allegedly "abandoned" property.

4. to enjoin the enforcement of 36 C.F.R. 2.12 for the purpose of silencing plaintiffs' drums.

5. to enjoin arrests of plaintiffs for alleged infractions of Title 36 when a C.F.R. Violation Notice would serve the same purpose as an arrest.

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The grounds for this motion are more explicitly set forth in an accompanying Memorandum.

For the Court's convenience a proposed Order is attached.

Respectfully submitted this 21st day
of March, 1991,

/s/ W. Thomas
William Thomas, pro se
2817 11th Street, N.W.
Washington, D.C. 20001
(202) 462-0757

/s/ Ellen Thomas
Ellen Thomas, pro se
2817 11th Street N.W.
Washington, D.C. 20001,

/s/ Brett Hamrick
Brett (Song) Hamrick
P.O Box 27217
Washington, D.C. 20001

/s/ Concepcion Picciotto
Concepcion Picciotto
P.O. Box 4931
Washington, D.C. 20008

/s/ Scott M. Galindez
Scott Michael Galindez
P.O Box 27217
Washington, D. C. 20001,

CERTIFICATE OF SERVICE

I, , hereby state that, on this 21st day of March, 1991 I caused a copy of the foregoing Motion for Preliminary Injunction to be hand-delivered to the offices of Jay B. Stevens, U.S. Attorney for the District of Columbia at Judiciary Square, 555 4th Street N.W., Washington, D.C., and the Office of the Corporation Counsel for the District of Columbia.

William Thomas

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