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 TEMPORARY RESTRAINING ORDER

INTRODUCTION

Pursuant to Rule 65, plaintiffs hereby petition the Court for an Order to (1) restore the status quo ante helium as embodied (between April 4, 1986, and February 3, 1991) in the display of plaintiffs' signs and distribution of literature in Lafayette Park, (2) to restrain defendants from threatening to arrest plaintiffs for maintaining a continuous presence in the park by establishing specific guidelines for "casual sleep" and "property," within the context of the "camping" regulation, thus checking against police force in the suppression of expression.

THE PROBLEM

Defendants' actions have severely chilled the exercise of plaintiffs' First Amendment rights. Due to the seizure of their signs and literature each plaintiff is now reluctant to bring other signs and literature into the Park for fear that those items will also be seized.

Plaintiffs believe that the pattern and practice of defendants and their agents in applying the regulations at issue place plaintiffs in immediate peril, if they so much as sit on a piece of cardboard in the park, of unlawful arrest as well as
physical and emotional injury.

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PRAYER FOR SOLUTION

Plaintiffs move the Court 1) to determine whether the specific signs and literature seized by defendants between January and March, 1991, which plaintiffs wish returned to Lafayette Park, are in substantial compliance with the provisions of 36 C.F.R (g)(x)(A)&(B), and 2) if found to be in substantial compliance, to order the return of the signs and literature, and 3) to temporarily restrain the seizure of those specific signs and comparable literature, and 4) to decide whether defendants should be restrained from the pattern and practice with which they have enforced 36 C.F.R (i)(1), the "camping" regulation, against plaintiffs.

A memorandum accompanies this Motion.

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, pro se
P.O Box 27217
Washington, D.C. 20001

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

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

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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, , hereby state that, on this 21st day of March, 1991 I caused a copy of the foregoing Renewed Motion for Temporary Restraining Order 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.

W.Thomas