Dixianne Hawks
13803 N. Granada Dr.
Magalia, Calif. 95954
Tel: (916) 877-6436

Appellant in Her Proper Person

John E. Wolfgram
4826 South Studebaker Road
Placerville, California 95667



               IN THE SUPREME COURT OF THE UNITED STATES




In re: DIXIANNE HAWKS,              No. _______________________
     Plaintiff-Appellant-Petitioner
                                    9th Circuit Court of Appeals:
      v.                            Appeal Case No. 95-16714
                                    Civil Case No. 93-82-WBS
                                    (Eastern District of Calif.)
COUNTY OF BUTTE, DISTRICT JUDGE
GARCIA, CIRCUIT JUDGES SCHROEDER,
CANBY, AND WIGGINS,                     DECLARATION OF
                                       JOHN E. WOLFGRAM
     Defendants-Appellees            IN SUPPORT OF PETITION
_______________________________/     FOR A WRIT OF MANDAMUS

NINTH CIRCUIT COURT OF APPEALS,

     Respondent
_______________________________/


     DECLARATION OF JOHN E. WOLFGRAM IN SUPPORT OF PETITION

     At El  Dorado County,  California, I  declare that  I am  an

honorably discharged Viet Nam Veteran Recon Marine. I am 51 years

old and have never been convicted of a crime above an infraction;

nor ever  found liable  for any breach of duty to anyone.  I am a

graduate of  the University  of  Wisconsin  and  of  Southwestern

University School  of Law.  The philosophy of law is an avocation

that has  become my  vocation. I am an American with a Disability

within the meaning of the Americans with Disabilities Act.


                Declaration of John E. Wolfgram:
                          Page 1 of 3


     In l991  I was  retained by  Friends of  Dixianne  Hawks  to

assist in  Her defense  of false  charges in Butte County which I

believed then, and know now, violated Her First Amendment Rights.

While assisting Her, I learned from Her constitutional philosophy

answers to  questions I  had asked  of  Constitutional  Law,  but

couldn't answer.  I was  impressed enough  with the merits of the

issues She raised that I have continued over five years to assist

Her in  Her petition for redress, pro bono.  I do not myself have

the financial ability to pay Her litigation costs.


                REGARDING PLAINTIFF'S IFP STATUS

     Over these  five years  I have, in my professional capacity,

come  to   know  Her   quite  well.   I  know   of  Her  economic

circumstances;   that She  is disabled  and that  Her  source  of

income is  Social Security.   On several occasions I asked Her to

contribute to  routine administrative costs.  Invariably She told

me that  She couldn't  and I  believed Her enough that I paid the

costs out of my own pocket.  I have been to Her house.  It is one

She built  herself, with  the help of friends.  Several years ago

it suffered  severe fire  damage  and  has  not  been  completely

restored.   Over the  years I  know that She had one car, about a

l977 Datsun,  all beat  up, inside  and out.  That was  Her  only

transportation.  She no longer has it.


                Declaration of John E. Wolfgram:
                          Page 2 of 3


               REGARDING THE MERITS OF HER APPEAL

     Perhaps the  best statement  that I  can make  is to declare

that  over   the  past   five  years  I  have  spent  over  1,000

uncompensated hours  studying, examining, evaluating and drafting

the issues  relevant to  Her case(s).  The only deficiency of Her

issues is that they are on the cutting edge of the law ... where,

in my  opinion, it  must go.   I  am  absolutely  sure  that  the

"radical" ideas  about the Petition Clause, addressed herein, and

in the Opening Brief to the Court of Appeals, are in fact the Law

of the Land;  albeit, the idea will take some getting used to.


                 REGARDING HER SIGNATURE HEREIN

     Ms. Hawks  lives about  100 miles from me.  She and I are in

touch by  electronic mail  through a  mutual  friend.  Thus,  She

reviewed the work on the brief and on this Petition, while it was

in progress.   All  signatures of  hers in this petition are hers

except the signature to the motion to proceed IFP. (The signature

on the  IFP declaration is hers.)  Because of the distance, (mail

takes up  to a  week) I  signed her  name with  her consent. I am

personally familiar with the facts.


                REGARDING THE STATEMENT OF FACTS

     By reason  of my  long association  with  this  case,  I  am

familiar with  the facts  and proceedings  in this  action.   The

statement of  facts in  the motion  to proceed  IFP  and  in  the

Petition for Writ of Mandamus, are true of my own knowledge.


     I declare the foregoing true under penalty of  perjury.


Dated:  January 11, l996           ______________________________
                                   John E. Wolfgram


                Declaration of John E. Wolfgram:
                          Page 3 of 3


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Hawks v. County of Butte et al.