PORTLAND — City officials have a narrow view of the rights of speech, assembly and petition that is wrong and offensive, Occupy Maine says in a memo filed Tuesday in its lawsuit over protesters’ encampment in Lincoln Park.

“Where others see ordinary people breathing life into their democracy and bravely drawing attention to rampant economic injustice in our midst, the City of Portland sees a ‘junkyard’ and a bunch of freeloading winter campers,” John Branson, the lawyer for Occupy Maine, wrote in the memo.

Branson filed the document in reply to the city’s response to the group’s initial court complaint.

Occupy Maine and the city are scheduled to present their arguments before Justice Thomas Warren on Jan. 24.

The hearing will include testimony and other evidence.

Occupy Maine sued the city in Superior Court last month, arguing that rules about the use of city parks and the City Council’s denial of a permit for the encampment violated the protesters’ rights.

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The city has issued a vacate order to Occupy Maine, but officials have promised to allow the protesters to stay in the park while the case makes its way through court.

The group argues that the nature of its protest relies on a sustained presence in a public space. That position is at odds with a city ordinance that bars people from public parks after 10 p.m.

The protesters argue that the ordinance is overly broad and gives the city manager too much discretion about when exceptions can be made.

Protesters have been staying overnight in Lincoln Park since October, though police say few, if any, have been there on some recent nights as temperatures have plunged.

In their lawsuit, the protesters say they were invited by the city to use the park as an alternative to their original base in Monument Square.

The city’s lawyers, however, say Lincoln Park was only a temporary solution while the sides researched their legal rights. The city argues that there have been problems in the encampment, including arrests and health and safety violations.

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In his filing Tuesday, Branson criticized the city for relying on a police officer’s affidavit to determine that protesters are not engaged in constitutionally protected forms of speech. Officer Nicholas Goodman noted that he had never seen Occupy Maine members marching, demonstrating or distributing pamphlets.

“Apparently blind and deaf to the events that have engulfed the nation since the fall of 2008 — and the nationwide protest movement that started on Wall Street in September of 2011 — the City contends that Occupy Maine and its members have been engaged in no activity other than camping, sleeping and eating since October 3, 2011,” Branson wrote.

He described regular general assembly meetings, working groups and other activities that promote civic discussion.

Nicole Clegg, the city’s spokeswoman, said the city is still reviewing Occupy Maine’s memo. She reiterated the city’s commitment to allowing protesters to stay in the park.

“If they decided to pursue this through the courts, we would allow that to play out,” she said.

Staff Writer Dennis Hoey contributed to this report.

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