Brian Willson Papers, 1985-1992

Contents List

Container Title
M91-198
Part 1 (M91-198): Original Collection, 1986-1992
Physical Description: 13.7 cubic feet (11 records center cartons, 3 archives boxes, 1 flat box, and 1 oversize tube) and 2 videorecordings 
Scope and Content Note

Papers of peace activist Brian Willson, documenting a September 1, 1987 incident in which a Navy train ran over Willson, severing his leg, during a demonstration by the group Nuremberg Actions in protest of U.S. government shipments of military aid to the Nicaraguan Contras. The collection consists of legal documents relating to Willson's subsequent lawsuit, as well as records of the various investigations, Willson's medical records, photographs, videotapes, and news clippings.

These papers have been arranged into six series, the largest of which contains the most important LEGAL DOCUMENTS AND EXHIBITS relating to that case, including the deposition by expert witness, radical historian Howard Zinn; INVESTIGATIONS by the Contra Costa County Sheriff's Department, the U.S. Congress, and others, Willson's MEDICAL RECORDS, and NEWS CLIPPINGS, PHOTOGRAPHS, and VIDEORECORDINGS about the incident. The collection documents not only the incident and the Navy's handling of it, but also the philosophies and peace activities of Willson, the Veterans Peace Action Team, the Veterans Fast for Life, and most notably, Nuremberg Actions.

Series: Legal Documents and Exhibits
Depositions
Box   1
Ballin, Christine, plaintiff witness, June 9, 1989
Box   1
Banta, John M., defendant, March 21 and June 13, 1989
Physical Description: 2 folders 
Box   1
Baron, Dr. Robert B., August 29, 1989
Box   1
Bell, Milo D., defense witness, September 15, 1989
Box   1
Berrol, Dr. Sheldon, October 10, 1989
Box   1
Bovard, Robert N., plaintiff witness, August 1, 1989
Box   1
Brooks, Stephen D., February 1, 1990
Box   1
Burke, John V., plaintiff expert, September 27, 1989 and February 5, 1990
Physical Description: 2 folders 
Box   1
Butigan, Kenneth M., plaintiff witness, February 8, 1990
Box   1
Cagle, Lonnie Francis, defendant, May 19 and May 22, 1989
Physical Description: 2 folders 
Box   1
Ching, Clayton W.K., March 27, 1989
Box   1
Coffy, Marilyn, plaintiff witness, July 18, 1989
Box   1
Cohen, H. Harvey, defense expert, March 2, 1990
Box   1
Conley, James E., defense witness, September 18, 1989 and February 5, 1990
Physical Description: 2 folders 
Box   1
Conner, Maybelle A., defense witness, June 16, 1989
Box   2
Davis, Clarence L., defense witness, August 8, 1989
Box   2
Dawson, Ralph, defendant, February 10, March 23, and June 26, 1989
Physical Description: 3 folders 
Box   2
De Lapp, Kenneth, November 14, 1989
Box   2
Densberger, John, defense witness, August 13, 1989
Box   2
Dorinson, Dr. S. Malvern, October 10, 1989
Box   2
Duncombe, David Cameron, plaintiff, March 31, 1989
Box   2
Earle, Albert Norris, August 7, 1989
Box   2
Earth, Ellen, plaintiff witness, March 3, 1989
Box   2
Elmer, Leroy H., plaintiff witness, April 25, 1989
Box   2
Falk, Richard, plaintiff expert, September 13, 1989
Box   2
Fields, Jimmy D., defense witness, January 24, 1989
Box   2
Fisher, William T., plaintiff witness, September 12, 1989
Box   2
Foster, Joan, defense witness, May 21, 1989
Box   2
Foster, Thomas, defense witness, June 16, 1989
Box   2
Freeman, William E., defense witness, January 25, 1989
Box   2
Fuller, Annette, plaintiff witness, August 1, 1989
Box   2
Goodmacher, Charles D., plaintiff witness, volume 2, August 22, 1989
Box   2
Hagan, Laura, plaintiff witness, February 1, 1990
Box   2
Hagen, E. Dan, defense witness, December 15, 1988
Hartsough, David R., plaintiff witness
Box   2
Volume 2, March 15, 1989
Box   3
Volume 3, August 2, 1989
Box   3
Herrera, Francisco, plaintiff witness, August 15, 1989
Box   3
Hilsabeck, Walter G., defense witness, September 20, 1989 and February 2, 1990
Physical Description: 2 folders 
Box   3
Holmes, Ovid Luttrell, August 7, 1989
Box   3
Hubbard, Edward W., defendant, January 6, August 10, and November 6, 1989
Physical Description: 3 folders 
Box   3
Hulbert, Slade F., plaintiff expert, October 12, 1989 and January 29, 1990
Physical Description: 2 folders 
Box   3
Humiston, David A., defendant, February 16, March 8, August 25, 1989 and January 30, 1990
Physical Description: 4 folders 
Box   3
Johnson, Dr. Ralph, defense witness, October 2, 1989
Box   3
Kayfetz, Paul, plaintiff expert, September 11, 1989 and April 18, 1990
Physical Description: 2 folders 
Box   3
Khatsianow, Feliks, plaintiff witness, February 9, 1990
Box   3
King, Paul, volume 2, February 14, 1990
Box   3
Koniuk, Wayne, January 8, 1990
Box   3
Kramer, B.E. Sam, plaintiff expert, October 16, 1989
Box   4
Kroll, Michael, plaintiff, March 30 and October 16, 1989
Box   4
La Forgia, Brian, October 9, 1989
Box   4
Labovitz, Roberta, plaintiff witness, June 22, 1989
Box   4
Landis, William D., August 7, 1989
Box   4
Lassalle, Robert A., plaintiff witness, May 12, 1989
Box   4
Lowery, Stanley D., defense witness, January 26, 1989
Box   4
MacRae, Robert A., plaintiff expert, excerpt, September 26, 1989 and February 5, 1990
Physical Description: 2 folders 
Box   4
McCallum, Patricia, plaintiff witness, September 22, 1989
Box   4
Martin, Jimmie Lee, defense witness, November 16, 1988
Box   4
Mayfield, Robert A., defendant, February 17, June 30, and August 23, 1989
Physical Description: 3 folders 
Box   4
Mays, George Glennon, defense witness, September 18, 1989
Box   4
Miceli, Joseph D., defense witness, September 21, 1989
Box   4
Murphy, Duncan, plaintiff, July 1 and July 31, 1989
Box   4
Nunn, Edwin L., defense witness, December 13, 1989
Box   5
Peri, Andrew J., plaintiff witness, February 15, 1989
Box   5
Phelps, William H., defense witness, November 30, 1988
Box   5
Piazza, Eugene S., defense witness, November 29 and June 14, 1988
Physical Description: 2 folders 
Box   5
Procter, Craig A., defense witness, July 14, 1988
Box   5
Pryzby, Stanley J., defense witness, July 25 and September 19, 1989
Physical Description: 2 folders 
Box   5
Rauen, Holley, plaintiff, August 11, 1988, September 25, 1989, February 6, 1990
Physical Description: 3 folders 
Box   5
Razak, Kenneth, defense witness, supporting document: Razak's deposition in 1984 case, September 29, 1989
Box   5
Reposa, Larry, defense witness, February 9, 1989
Box   5
Resendez, Renee, plaintiff witness, October 3, 1989
Box   5
Robert, Dr. Cavett M., February 15, 1990
Box   5
Rotzler, Frederic, defense witness, July 28, 1989
Box   5
Rutherford, Scott, plaintiff witness, June 8, 1989
Box   6
Scarper, Lynne, plaintiff witness, October 11, 1989
Box   6
Schoos, Richard, plaintiff witness, January 17, 1990
Box   6
Seaman, Marie M., plaintiff witness, September 1, 1989
Box   6
Skerce, John, plaintiff witness, April 13, 1989
Box   6
Spitzer, Robert, plaintiff witness, April 4 and August 3, 1989
Box   6
Stokes, Abner C., defense witness, January 24, 1989
Box   6
Troyan, Stephanie, plaintiff witness, October 9, 1989
Box   6
Umholtz, Thomas, plaintiff witness, July 20, 1989
Box   6
Villen, Sydney, plaintiff witness, March 17, 1989
Box   6
Von Zabern, Dominic, plaintiff witness, June 22, 1989
Box   6
Wall, Marjorie J., plaintiff witness, August 15, 1989
Box   6
Warren, Michael J., defense witness, August 4 and September 20, 1989
Box   6
Williams, Helen S., plaintiff witness, August 14, 1989
Box   6
Willson, S. Brian, plaintiff, lawyer's note, January 10, February 3, February 28, March 1, August 28, 1989
Physical Description: 5 folders 
Box   6
Wright, Robert E., January 19, 1990
Box   6
Zinn, Howard, plaintiff expert, October 6, 1989
Box   6
Zwickel, Abraham, plaintiff witness, April 25, 1989
Box   13
Abar, G. Gilman, July 11, 1989
Box   13
Atwater, Raymond Dale, January 25, 1989
Box   13
Avignone, Joseph, July 27, 1989
Banta, John
Box   13
Summary
Box   13
Notes
Box   13
Bell, Milo D., summary
Cagle, Lonnie
Box   13
Summary
Box   13
Short summary
Summary
Box   13
Ching, Clayton
Box   13
Coffy, Marilyn
Box   13
Dawson, Ralph
Physical Description: 3 folders 
Box   13
Duncombe
Box   13
Earth
Box   13
Goodmacher
Box   13
Hartsough
Physical Description: 2 folders 
Box   13
Herrera
Box   13
Hubbard
Box   13
Larson, Harry, December 12, 1988
Box   13
Lassalle
Box   13
Rauen
Box   13
Razak
Box   13
Willson
Box   7
Summons and Complaint for Damages (Intentional Infliction of Mental Distress; Civil Conspiracy; Negligent Infliction of Mental Distress; Violation of Statute), January 8, 1988
Note: Train crew vs. Willson, with manuscript notes.
Box   7
Attachments to S. Brian Willson Claim, January 19, 1988
Box   7
Attachments to Holly Rauen Claim, January 19, 1988
Box   7
Complaint, January 28, 1988
Box   7
Answer to Complaint, Counterclaims, and Cross-claims by Defendant Robert Mayfield, March 10, 1988
Box   7
Answer to Complaint, Counterclaims, and Cross-claims by Defendant Ralph Dawson, March 30, 1988
Box   7
Answer to Complaint, Counterclaims and Cross-claims by Defendant David Humiston
Box   7
Defendant John Banta's Answer to Complaint, April 1, 1988
Box   7
Answer of Defendant Hubbard, April 1, 1988
Box   7
Cross-claim for Indemnity and Apportionment of Fault, April 1, 1988
Box   7
Answer to Complaint by Defendant Captain Lonnie F. Cagle, April 18, 1988
Box   7
Counterdefendants' Answer to Counterclaims of Ralph Dawson, David Humiston and Robert Mayfield, April 18, 1988
Answer to the Cross-Claim for Indemnity and Apportionment of Fault of John M. Banta, April 19, 1988
Box   7
Robert Mayfield
Box   7
David Humiston
Box   7
Ralph Dawson
Box   7
Order Denying Motion to Substitute United States as Defendant, May 4, 1988
Box   7
Memorandum and Order Regarding Defendants' Motions to Dismiss, September 23, 1988
Box   7
First Amended Complaint, October 13, 1988
Box   7
Answer to First Amended Complaint by Defendant Captain Lonnie F. Cagle, October 28, 1988
Box   7
Answer of Defendant Robert Mayfield to First Amended Complaint, Counterclaims and Cross-claims, November 2, 1988
Box   7
Answer of Defendant Ralph Dawson to First Amended Complaint, Counterclaims and Cross-claims, November 2, 1988
Box   7
Answer of Defendant David Humiston to First Amended Complaint, Counterclaims and Cross-Claims, November 3, 1988
Box   7
Defendant John M. Banta's Answer to First Amended Complaint, November 4, 1988
Box   7
Answer of Defendant Hubbard to the First Amended Complaint, November 7, 1988
Box   7
Counter-defendants' Answer to Counterclaims of Ralph Dawson, David Humiston, and Robert Mayfield in Answer of Each of Above Defendants to First Amended Complaint, Counterclaims and Cross-claims, November 9, 1988
Box   7
Answer of Captain Lonnie F. Cagle to Cross-claims by Defendant Ralph Dawson, November 14, 1988
Box   7
Answer of Captain Lonnie F. Cagle to Cross-claims by Defendant David Humiston, November 14, 1988
Box   7
Answer of Captain Lonnie F. Cagle to Cross-claims by Defendant Robert Mayfield, November 14, 1988
Box   7
First Set of Interrogatories to Plaintiffs, December 8, 1988
Box   7
Defendants' First Set of Interrogatories to Plaintiff Holly Rauen, December 9, 1988
Box   7
Answer of United States of America to First Amended Complaint, December 19, 1988
Box   7
Defendant Cagle's Interrogatories to Plaintiff, January 26, 1989
Box   7
Declaration of Margaret Ratner, February 2, 1989
Box   7
Nuremberg Actions' Reply to Opposition to Motion to Quash Subpoena Duces Tecum, February 27, 1989
Physical Description: 2 folders 
Box   7
Plaintiffs' Amended or Supplemental Responses to Defendant Banta's Request for Production of Documents, et cetera, June 2, 1989
Box   7
Plaintiffs' Amended Responses to Requests number 3 and 4 of Defendant Cagle's Requests to Plaintiffs for Production of Documents, etcetera, June 2, 1989
Box   7
Requests for Admission, September 12, 1989
Box   7
Plaintiff Brian Willson's Answers to First Set of Interrogatories Propounded by Defendant United States of America, October 12, 1989
Box   7
Plaintiffs' Response to Defendant United States' Requests for Admission, October 12, 1989
Orders
Box   7
December 29, 1989
Box   7
January 2, 1990
Box   7
Joint Settlement Conference Statement on Behalf of All Plaintiffs, February 9, 1990
Box   7
Declaration of Assistant United States Attorney John F. Penrose, May 14, 1990
Box   7
Notice of Motion and Motion in Support of Memorandum of Motion for Additional Production from Documents of Nuremberg Actions, May 17, 1990
Box   7
Reply Memorandum of United States regarding Motion for Additional Document Production from Nuremberg Actions, June 15, 1990
Box   7
Plaintiffs' Objections to Defendant John M. Banta's Interrogatories, June 18, 1990
Box   7
Plaintiffs' Objections to Defendant John M. Banta's Request for Production, June 18, 1990
Box   7
Declaration of Jonathan D. Melrod in Support of Plaintiffs' Opposition to U.S. Government's Motion regarding Review of Redacted Documents, June 22, 1990
Box   7
Declaration of Judy Alexander, June 22, 1990
Box   7
Opposition of Nuremberg Actions to Defendants' Motion for Additional Production with Opposition of Nuremberg Actions to Defendants' Memorandum regarding Review of Redacted Documents, June 22, 1990
Box   7
Declaration of Thomas Steel in Support of Plaintiffs' Opposition to Government's Motion regarding Nuremberg Action Redacted Documents, June 22, 1990
Box   7
Reporter's Transcript of Proceedings, June 22, 1990
Box   7
Plaintiffs' Opposition to U.S. Government's Motion regarding Review of Redacted Nuremberg Documents, June 22, 1990
Box   7
Defendant's Proposed Order regarding Production of Documents by Nuremberg Actions and Lynne Scarper, June 26, 1990
Box   7
Nuremberg Actions' Proposed Order regarding Defendant's Motion for Additional Production of Nuremberg Actions' Documents, June 27, 1990
Box   7
Declaration of Assistant United States Attorney John F. Penrose regarding Opposition to Plaintiffs' Motion for Partial Summary Judgment, June 28, 1990
Box   7
Response of Plaintiff Brian Willson to Request of Defendant United States for Production, June 1990
Box   7
Opposition Memorandum of United States to Plaintiff's Motion for Partial Summary Judgment, July 12, 1990
Box   7
Memorandum of Points and Authorities in Support of Motion in Limine to Bar Evidence or Argument in Support of Defenses Based on the Justification Necessity or Compliance with International Law, July 30, 1990
Box   7
Defendant's Motion in Limine to Exclude Testimony of Richard Falk and Howard Zinn, August 15, 16, 1990
Summary Judgments and Significant Orders
Summary Judgment motions including best summary of Willson evidence
Box   7
Plaintiffs' Memorandum in Opposition to Motions of Indivdual Defendants for Summary Judgment and/or for Separate Trials, October 12, 1989
Box   7
Plaintiffs' Memorandum in Opposition to Defendant Cagle's Motion for Summary Judgment
Assumption of the Risk, Summary Judgment Pleadings
Box   7
Opposition Memorandum of United States to Plaintiff's Motion for Partial Summary Judgment, July 12, 1990
Box   7
Memorandum of Points and Authorities In Support of Plaintiffs' Motion for Partial Summary Judgment, April 16, 1990
Significant Orders: District Court and Court of Appeals
Box   7
Appeal from the United States District Court for the Northern District of California, Robert F. Peckham, District Judge, Presiding, Argued and Submitted September 15, 1989, Memorandum
Box   7
Orders, January 2, 1990
Box   7
Memorandum and Order Regarding Defendants' Motions to Dismiss, September 1988
Box   7
Trial Simulation, jury, Willson et al. v. Cagle et al., July 17, 1990
Box   12
Photographs of simulation of incident, “Visibility Studies of Conductor's, Brakeman's and Engineer's View When Front of Train at Indicated Distances from Willson”
Physical Description: 3 volumes 
Exhibits
Box   13
Volume 1-3
Box   14
Volume 4-5
Box   15
Volume 6
Oversize Tube  
Line drawing of incident site
Series: Investigations
Box   7
Willson's lawyer, “Report of Investigation Relating to Criminal Responsibility for Injuries Suffered by S. Brian Willson on September 1, 1987”
Congressional, House Armed Services Committee Subcommittee on Investigations
Box   7
“Concord Naval Weapons Station Train Incident, Hearing....,” November 18, 1987
Box   7
“Statement of Captain Stanley J. Pryzby, U.S. Navy Director, ...before the Investigation Subcommittee,” November 18, 1987
Box   7
“Summary of Events of September 1, 1987 at the Concord Naval Weapons Station,” November 18, 1987
Box   7
“Testimony of Philip Olekszyk, Deputy Associate Administrator for Safety, Federal Railroad Administration...,” November 18, 1987
Box   7
Draft report, “Concord Naval Weapons Station Train Incident,” December 1987
Box   7
“Concord Naval Weapons Station Train Incident, Report of the Investigations Subcommittee...,” December 1987
Box   8
Department of the Navy: Investigation to Inquire into the Circumstances Connected with the Train Accident Resulting in Injuries to Mr. Brian Willson (Civilian), which Occurred in Contra Costa County, California, in the Vicinity of Naval Weapons Station Concord, on September 1, 1987
Physical Description: 3 folders 
Box   8
Contra Costa Sheriff, investigation records, press release, September 22, 1987
Physical Description: 2 folders 
Box   15
Contra Costa Sheriff investigation records
Box   15
Transcript of Detective Nunn interview with Willson
Series: Medical Records
Box   8
Sibley Memorial Hospital
Box   8
John Muir Hospital
Box   8
Diablo Neurological Medical Group
Box   8
Neuro Scan
Box   8
Medical bills, Washington, D.C., November 1987
Box   8
Wayne Koniuk, Prosthetist
Box   8
Cavett, M. Robert, M.D.
Box   8
Medical records and bills
Box   8
Medical bills, general
Box   8
Physical therapy, Tom Koren
Box   8
Sheldon Berrol, M.D.
Box   8
Norman Livermore, M.D.
Box   8
Clayton Heatley
Box   8
Ross, Isabel
Box   8
Dr. Barron
Box   8
Omega Medical Clinic
Box   8
John Muir Hospital
Box   8
Blood Bank, Alameda Medical Association
Box   8
Lindsay Gillis, M.D.
Box   8
Diablo Valley Radiology
Box   8
Crescent Health Services
Box   8
Donald Hay, M.D.
Box   8
Steven S. Jacobs, M.D.
Box   8
Dewey Sanberg, M.D.
Box   8
Wong, Nang, M.D.
Box   8
Gregory Anderson, M.D.
Box   8
Lawrence Orthotics and Prosthetics
Box   8
Nourollah Ghorbani, M.D.
Box   8
Lawrence G. Tew, M.D.
Box   8
Lawrence Orthotics and Prosthetics
Box   8
Medical Notes regarding condition and problems
Box   8
Plaintiffs' expert, Carol Hyland
Box   8
Dorinson, Malvern, psychiatrist
Box   8
Hilly Harned
Box   8
Brian La Forgia
Box   8
John Muir Hospital
Physical Description: 2 folders 
Box   15
John Muir Hospital
Box   12
Willson's x-rays
Series: News Clippings
Box   10
From press service, 1987-1990
Box   11
General, 1987
Series: Photographs
Box   9
Photographs, negatives, and contact sheets with inventory
Scope and Content Note: Images include the protest and train incident of September 1, 1987, and Willson in the hospital.
Oversize Tube  
Photograph of collage made by St. Paul, Minnesota veteran for Brian Willson
Series: Videorecordings
Physical Description: VHS tapes 
VHA 192
Incident, September 1, 1987
Note: Robert Spitzer, videographer.
VHA 191
6.05 minutes in slow motion and zooms
Note: Robert Spitzer, videographer.
M94-084
Part 2 (M94-084): Additions, 1989-1992
Physical Description: 0.4 cubic feet (1 archives box) 
Scope and Content Note: Additions, 1989-1992, including depositions given in the case Willson vs. Cagle; a speech given by Willson in Panama, December 1991; and flyers for Willson's organization, Community for the Practice of Non-Violence.
M95-151
Part 3 (M95-151): Additions, 1985-1986
Physical Description: 4.5 cubic feet (4 records center cartons, 3 card file boxes, and 1 flat box), 76 photographs, and 5 videorecordings 
Scope and Content Note: This addition relates entirely to the Veterans Fast for Life, a peace action protesting U.S. policy in Nicaragua in which Willson participated during 1986. Materials include primarily letters of support for the protest. Also included are photographs; background material; and videorecordings related to the movement.
Box   1-4
Letters from supporters, 1986
Box   4
Folder   40
Negative and unusual letters
Box   4
Folder   41
Press releases, citations, manual and other background
Box   4
Folder   42
Speech notes (Brian Willson?), 1985-1986
Box   4
Folder   43
Charlie Liteky
Box   4
Folder   44
Poetry
Box   4
Folder   45-47
Clippings
Box   5-7
Postcards from supporters, 1986
Box   8
Banners made by the children of St. John of God, San Francisco, California
Physical Description: 7 banners 
Photographs
PH Box   25
Folder   1
Fasters and related subjects, Washington, D.C.
PH Box   25
Folder   2
Miscellaneous images, Washington, D.C., including Willson with Senator Ted Kennedy
PH Box   25
Folder   3
A California demonstration in support of Veterans Fast for Life
PH Box   25
Folder   4
Miscellaneous demonstrations in support of Veterans Fast for Life
PH Box   25
Folder   5
Chaplain Charlie Liteky in military uniform
Film Archive
Videorecordings
Physical Description: VHS tapes 
Interviews with fasters and supporters and other related events, Washington, D.C., September-October 23, 1986
Physical Description: 2 tapes 
“Veterans Fast for Life,” produced by Science and Behavior Books, Palo Alto, California; interviews with fasters and supporters
Charles Liteky and Bill Gandall speaking at a Meeting of the Florida Coalition for Peace and Justice, December 12, 1986
“I Witness: Nicaragua,” produced by Martha Mollison and the Somerville Producers Group; interviews with eleven guests who have been to Nicaragua, September 23, 1986
M96-019
Part 4 (M96-019): Additions, 1986-1988
Physical Description: 0.2 cubic feet (1 archives box) 
Scope and Content Note: Additions, 1986-1988, consisting mainly of press coverage and press releases of Veterans Fast for Life/Veterans Peace Action Teams. Also included are clippings of interviews with Willson and clippings about related topics.
Audio 1738A
Part 5 (Audio 1738A): Addition, 1987
Physical Description: 1 cassette recording 
Scope and Content Note: Audio recording of an informal talk given by David Hartsough on September 7, 1987 entitled, “The Witness of Brian Willson.”