United States v. Rainbow


UNITED STATES DISTRICT COURT
THE MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION

UNITED STATES OF AMERICA             
                                                    Civil Action
           v.                                       Case Number 96- 183 

THE RAINBOW FAMILY, et al.

DECLARATION OF WILLIAM THOMAS

I, William Thomas, in support of my motions to Intervene in and Dismiss the above entitled case, submitted herewith, and pursuant to the provisions of Rule 11, or such appropriate authority, hereby declare under penalty of perjury, that the following is a true and accurate representation of my beliefs and actions:

1. My religion is devotion to pursuit of Truth, Justice, Freedom and Equality, which I believe to be "the things of the Kingdom of Heaven." Luke, 12: 31; Matthew 6: 33; John, 18: 36.

2. I believe that through reason, thought, and expression humanity can draw closer to understanding the ways of God. Isaiah 1: 18.

3. Based on my belief in a God of reason, the most significant exercise of my religion is to assemble fellow seekers of Truth, Justice, Freedom and Equality. Matthew 18: 20; Acts 2: 44.

4. My association with the Rainbow Family began and has continued as a result of the regulatory scheme that culminated in the amendments to 36 CFR 251 and 261, which are the subject of this suit. In my opinion these regulations are a serious threat to freedom of thought, expression, assembly, and, as such, constitute an insult to the principles of my devotion (supra, 1), and those "self evident truths" upon which this nation was founded.

5. My involvement in the aforesaid scheme has consisted in assembling and disseminating information regarding the procedure of the scheme to interested individuals.

6. As a result of my efforts to prevent the Forest Service from criminalizing the ancient right of free assembly on public lands, .my address, P.O. Box 27217, Washington, and telephone number 202-462-0757 appears under the constitutional opinions relied upon on the Complaint, i.e.:

"The 'Rainbow Guide for 1995, Summer Edition' indicates that the forest Service group use regulations are unconstitutional under the First Amendment to the U.S. Constitution. See Attachment 1." Complaint, 22.

7. Owing to the intimate association of my personal address and telephone number with the legal opinions of which plaintiff complains, considering also that plaintiffs ask the Court to "Order the defendants to take such affirmative actions as to provide notice of the injunction to Rainbow Family members inform all means of available public and private media and to inform all members of the Rainbow Family that a violation of the injunction is punishable by contempt of this court," my personal interests are imperiled by plaintiff's action.

8. A federal court determination as to whether a federal regulation, applicable to all federal forests in the United States, does, or does not, "comply with the First Amendment of the United States Constitution and (is) otherwise legally valid," will seriously affect my personal interests.

9. Although page 3 of Complaint Attachment 1 states, "If you have a belly button, you can be a Rainbow," notwithstanding the fact that I have a belly button, I am not representing myself as a member of the Rainbow Family, but only as an individual concerned with freedom of thought, expression and assembly.

10. I certainly have no authority, nor can I honestly profess, to represent any interests the which purported "Rainbow Family class" may, or may not, have.

11. I reaffirm, under penalty of perjury, and applicable statutes, that the foregoing is true and accurate to the best of my knowledge and recollection.

William Thomas
March 15, 1996


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