United States v. Rainbow
UNITED STATES DISTRICT COURT
THE MIDDLE DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
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
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.
March 15, 1996
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