UNITED STATES OF AMERICA, Plaintiff, vs. CASE NO. 96-183-Civ-J-20 WAKEEM AKA WILLIAM A. BARRIE, Defendants.
STATE OF FLORIDA
COUNTY OF MARTIN
The undersigned, Wakeem a/k/a William L. Barrie, does hereby depose and swear to the following:
The undersigned is merely someone who attended the "Gathering" in the Osceola National Forest in Florida during the first part of February, 1996. I have never before attended a gathering in Osceola. To the best of my knowledge, that event is over, and is not scheduled to be repeated in 1996.
The issues raised in the complaint concerning the different legalities can therefore not be properly addressed by this Court because, as I understand it, the controversy or Subject Matter is no longer before this Court. Additionally, without something from which to draw facts, this Court will be without adequate defendants to contest the legal assertions of the complaint, deeming the Government's Motion for Declaratory Judgement moot as a mere opinion, absent challenge or fact.
As alleged in Paragraph 4 of the United States Complaint, I am not, nor ever have been a "member" of the Rainbow Family et al, described as a "losely knit organization of persons gather together in the national forest to celebrate peace and harmony with nature and with one another". This Affiant has never applied for, nor received any form of membership into this "loosely knit organization".
Accordingly, I am wholly without any knowledge or means to contact or represent any members of this "loosely knit organization". I haven't a real clue as to how to address any of the issues presented in the complaint, and cannot with any credibility claim to be able to do so for any other person or organization, particularly a "loosely knit organization".
As per paragraph 5 of the United States Complaint, I don't know what it's talking about when it mentions my name.
As can be discerned from the atached Affidavit of Indigency, this affiant is without funds to hire an attorney.. A friend helped me drafty these documents. Accordingly, as the Government alleges in Paragraph 7 (d) cannot "fairly and adequately represent the interests of the Class." In reference to 1, above, I also have no "requisite personal interest in the outcome of this action". (Paragraph 7d)
Following that line, the United States alleges in Paragraph 6 that "class members have acted or refused to act on grounds generally applicable to the class." Personally, I don't have a clue about what that means, or whether or not it's true, or whether or not it's supposed to state something about how I have "acted or refused to act". If I am included in that allegation, the government cannot claim to have any more knowledge than I do. And I don't.
In consideration of the above, I cannot see how this Court can allow the United States Government to permit this Affieant to be obligated to represent the rights and interests of this "loosely knit organization" just because I happened to be attending one event.
RESPECTFULLY SUBMITTED THIS 13th DAY OF MAY, 1996,
William L. Barrie a/k/a Wakeem Notary Seal