THOMAS v. REAGAN

USDC Cr. No. 84-3552

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

WILLIAM THOMAS, et al    
     Plaintiff Pro Se    
                         
versus                          CA 84-3552
                                Judge Louis Oberdorfer
UNITED STATES, et al     
     Defendants

DECLARATION OF ROBERT DORROUGH RE
MARCH 16, 1987

I, Robert Dorrough, declare under penalty of perjury that the following is accurate and correct to the best of my knowledge:

1. On March 16, 1987, at about 11:33pm I saw U.S. Park Police officer Burnett walking east on the North side of Pennsylvania Avenue on the sidewalk bordering Lafayette Park. He went from demonstration site to demonstration site rousting the demonstrators and proclaiming: "Good Morning." When he arrived at my demonstration site I asked him for the time.

2. At about 1:08 am on March 17, 1987 officer Burnett repeated the procedure of rousting everyone and proclaiming "Good Morning." I again asked him what time it was. He inquired why I was asking about the time. I told him that I was keeping a record and that he last behaved this way at 11:33.

3. At about 2:30 am officer Burnett sat in a vehicle with another officer, who was blowing the horn. After approximately ten minutes I walked over to the car. Officer Burnett, sitting in the passenger's seat, rolled down his window. I told them that I thought they were being a nuisance, and asked them to move along. Officer Burnett responded with a threat to enforce the restriction of being more than three feet away from my signs against me. I returned to my demonstration site.

4. After about five minutes or ten honks or the cars horn I returned to the automobile and asked for the driver's name. After a lengthy word game the driver asked whether I knew the English language. When I replied in the affirmative, he asked whether I knew the letters of the alphabet. I indicated that I did. The officer then said: "Alright, I am only going to do this once. C-O-V-I-N-G-T-O-N." He blurted out, as fast as possible.

5. At about 3:10 am an unidentified Sergeant drove up behind the cruiser occupied by officers Burrnett and Covington, and entered a discussion with the two officers. Then the sergeant walked toward me as Burnett and Covington rousted the other demonstrators. I told the sergeant that I considered the officers' behavior to be harassment. He said that he had complete control of the two officers and that they were joking around in their interaction with the other demonstrators. I asked whether an objective observer might not consider the behavior of the officers, rather than the demonstrators to be a nuisance, and abridgment of the peace. Without explanation the sergeant ran to his vehicle, and sped away.

6. At about 3:45 am and on into the hours of dawn officer Covington repeatedly drove by the signs honking his horn.

Sworn to this ____ day of March, 1987

_________________________________

Robert Dorrough

Contents

Case Listing --- Proposition One ---- Peace Park