Legion for the Survival of Freedom, Theodore O’Keefe, Thomas Marcellus, Mark Weber and Greg Raven
Foundation to Defend the First Amendment, Liberty Lifeline Foundation, Willis Carto and Elisabeth Carto
Case No 719141, Superior Court of the State of California for the County of Orange
Declaration of Tom Marcellus
I, Thomas J. Marcellus Declare and State:
Open this door.There was no response so I pulled harder, the door opened, and Weber, O’Keefe, Raven and I entered the premises to attempt to secure them.
Get out — this is a civil matter.The unknown men, now assisted by Elisabeth Carto, were attempting to force us back out the door. One of them grabbed my arm. A general melee erupted. Elisabeth Carto began swinging her fists at Mark Weber.
Let go.Carto would not, and so I began towing Carto, club and all, toward the front door in order to remove him from the premises. With the weapon disabled, O’Keefe was able to assist me. I did not see O’Keefe strike Carto, and I did not strike Carto. As O’Keefe and I were pulling Carto toward the front door, I managed to dislodge the club from Carto. I did not strike Carto or threaten to strike him with it.
cash, glue to stop locks, chains, locks, keys, sledge, crowbar, clubs.Another note dated October 14, 1993 concerns the
rent in Costa Mesawherein a Carto employee in Washington, D.C., Blayne Hutzel, is instructed:
Do not deposit anything,which I believe means that the Legion’s rent checks were not to be cashed.
to take possessionof the property.
I declare under penalty of perjury and the laws of the State of California that the foregoing is true and correct.
Thomas J. Marcellus
October 17, 1993