Deputy Mayor Cas Holloway wrote in the motion that giving the protesters full run of the park would lead to re-creation of the "unsafe and unsanitary conditions and the substantial threat to public safety" that the city said led to the eviction. There was evidence, he wrote, that the protesters were stockpiling weapons. Mr. Holloway described a "steady accumulation of combustibles, smoking, and other hazards" at the site and said that makeshift weapons, "such as cardboard tubes with metal pipes inside, had been observed among the occupiers' possessions," and that after the Oct. 1 Brooklyn Bridge march, "knives, mace and hypodermic needles were observed discarded on the roadway."Thus," he added, "it was our understanding that the protesters may have had a significant number of items that could potentially be used as weapons.