Plaintiffs, Pro Se               )   
                                      )   CA 88-_____________
versus                                )   
                                      )   Judge _____________
RONALD WILSON REAGAN, et al,          )  
     Defendants                       )


I, Mary Huddle, plaintiff, pro se, in the above entitled action, hereby declare under penalty of perjury and as God is my witness, the following declaration includes factual details as best as I remember them:

1. In December of 1987 I was motivated to quit my job, forsake all of my material possessions and leave the comforts of my house to become a peace demonstrator in front of the White House.

2. After college I had sought to institute change through working in a few jobs -- still being in the system. Those jobs were unfulfilling and left me feeling like I was making little difference in anyone's life.

3. I was doing little more than working all day, paying for rent and food, and doing things out of love only when I had the time. Worse than that, at least 18% of my income was going in taxes towards war and weapons. To me the idea that part of my work time was going towards a bullet that would pierce someone's heart was repulsive.

4. I felt like a hypocrite! In order to secure my own comfort I would compromise my values so easily.

5. I have been involved with many political organizations and movements in the last five years, but what I saw in Peace (Lafayette) Park moved me very deeply.

6. A group of individuals, sharing the common goal of peace on earth through compassion and communication, had sacrificed their reasonable living accommodations (comfort, security, privacy, etc.) to share their ideals and visions with all who passed their way. In fact, I became living proof of their effec-tiveness when I joined them.

7. In a world wrought with war, hunger and injustice, I feel that the noblest profession is to speak out against the madness. The White House sidewalk is an excellent forum in which to do this. Because I live on faith in God, that He will provide for my needs, I can now spend my time communicating with people and inspiring the hopeless.

8. I believe in God's Law: "Do unto others as you would have them do unto you." Therefore I try to show love and respect to all people, especially those of my brothers and sisters who, out of rejection, loneliness and desperation find themselves living on the streets ... outcasts of "society."

9. I consider myself a follower of the teachings of Jesus the Christ, who also spent his life preaching to the people about faith in God and the kingdom of heaven. Jesus and his disciples followed a simple lifestyle very similar to that which we are demonstrating in front of the White House. I truly believe that my religion mandates that I preach the gospel, seek truth, relieve physical suffering and spiritual bondage. Right now, God wills me to be doing what I am doing in front of the White House.

10. Freedom of speech, freedom of religion and the free exercise thereof are much revered and time-honored traditions in this country, as well as rights guaranteed under the First Amendment. I must say I have been shocked and disgusted by the flagrant disregard of these rights displayed by the U.S. Park Police, the National Park Service and other employees of the U.S. government.

11. I have sacrificed personal comfort, cleanliness, privacy and material wealth in order to do my work in front of the White House. In return I have been subjected to police harassment and intimidation tactics ... I have been treated like a common criminal. My experience makes it seem as if the regula-tions passed over the last few years have been deliberately constructedto hamper people's ability to hold a 24 hour vigil in front of the White House. I have carefully studied these regula-tions, and my interaction with police officers convinces me that they are sufficiently vague to allow for arbitrary and selective enforcement practices. The camping and sign-size regulations have also been stretched to the limit to prohibit many symbolic, expressive and meaningful activities which could be conducted in front of the White House. Now to cite some examples upon which I base these allegations:


12. On numerous occasions during daytime and evening hours, officers of the U.S. Park Police have come by my demonstration site taking pictures of me and my companions or guests. Having committed no criminal offence, I resent having my picture taken by the police, without explanation; not to mention the fact that this surveillance frightens off people, therefore hampering my ability to communicate.

13. In December of 1986, before I was ever even a demonstrator in the park, I was just watching friends' signs for them. An officer approached me saying, "Can I see some identi-fication?" When I said, "I don't have any," he said, "What is your name and Social Security number?" I said, "I don't think I have to give it to you because I haven't done anything wrong." He said, "You are in violation of 36 CFR, Section ____, and can be cited for illegal camping."

14. As I knew no better at the time I gave him my name and number. In effect I was just visiting the park for a short time. Nothing I was doing was in violation of the regulation, so this officer had lied to me in order to get more information on me.

15. Since I have been in Peace Park, it has become routine that nearly every day an officer approaches my demonstration site requesting the name of the person(s) in charge of the demonstration. As no permit is required for demonstrations under 25 people, I feel this request unnecessary and in violation of my privacy.

16. One morning in September, 1988 I was approached by one Officer Thompson who told me I had "too much stuff" at my sign. He told me I was in violation of the storage of property regulation. He told me I shouldn't watch homeless people's belongings and said, "take the stuff and throw it in the trash can." The officer left without telling me how much was "too much stuff." I do not believe that I have any responsibility to throw a homeless person's belongings in the trash just because I am in a public park. Because I wouldn't want someone to throw my things in the trash, I sincerely believe that it would be a violation of my religious beliefs to throw someone else's stuff in the trash.

17. At 10:00 AM, September 29, 1988, one Sgt. Kuster approached my demonstration site and requested my name. Not wanting a hassle, and having told them my name countless times anyway, I told him. Sgt. Kuster then asked the person with the sign right next to mine, Bakta Noah Shatonomer, to give his name. When said individual would not give his name, but pointed to the longer version of it on his petition, the sergeant said, "Are you aware of 36 CFR? If you don't give me your name I'll take you downtown." He also said, "You see my face, remember it and next time I come around you better give me your stinkin' name."

18. In the course of my 24 hour vigil I have been unable to avoid intermittent and involuntary periods of casual sleep. But, together with Philip Joseph, I have gotten a permit from the Park Service, which allows me to conduct a 24 hour vigil, and I am not doing anything except what that permit allows. On countless occasions I have been startled by Park Police officers pounding their clubs on my wooden signs, saying I better wake up; even when I haven't been sleeping, demanding that I sit up, or I would be charged with a violation of the regulations. This threatening behavior I find very emotionally damaging, a physical strain, and entirely unnecessary, especially when I know well from my reading of the regulations that causal sleep in a public park is not against the law.

19. Perhaps the most disturbing encounter I have had with officials of the National Park Service occurred on September 8, 1988. I had applied for a permit to conduct a week-long demon-stration called "Free Aid" in Lafayette Park. The purpose of this event was to demonstrate "Love your neighbor as yourself." The activity was intended to include the distribution of blan-kets, free clothing and hot meals to the "street people." I believe that there is a serious practical need for more people to provide these services for the needy because they are constantly coming by my signs asking me for these things.

20. I was called in for a meeting to discuss my permit application with Fran Wigglesworth and Rick Merriman of the permits division of the NPS, Captain Barrett and Sgt Gessiotto of the U.S. Park Police and Randy Myers of the Interior Department, Solicitor's Office. I was accompanied by William Thomas. In the meeting I was told by the aforementioned officials that I would not be permitted to distribute food because if I set a pot of food on the ground it would be an illegal structure, in violation of the sign regulation. And I would not be permitted to distribute blankets because if I placed a stack of blankets on the ground it would be considered "storage of property," a violation of the camping regulation. Mr. Thomas and I were accused of trying to "get around" the Lafayette Park regulations. As my intent was not to store any food or blankets, nor to keep these things for myself, but to distribute them to others, it seems apparent to me that it is the Park Service who is trying to "get around" my freedom to do what I believe is right, and of doing something which is not hurting anyone, but is helping some people. By stretching regulatory application beyond any reason-able boundaries it seems that the Park Service can only be mis-using its power by using a "permit" to prohibit me from doing what anyone should reasonably be allowed to do without a permit.

21. These are only a few examples of the many incidents I have witnessed during my stay in Lafayette Park. From these incidents I feel that my constitutional rights are being whittled away by an administration which seeks to stifle any views differ-ent than the illusion which it maintains.

22. I beg the court to issue an injunction to stop arbitrary and selective enforcement of administrative regulations and police harassment aimed at individuals who are trying to fulfill their civic obligations as citizens of this country, and their moral obligations as children of God.

Under penalty of perjury,
this 30th day of September, 1988,

Mary Huddle
P.O. Box 27217
Washington, D.C. 20038