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


I, Philip Joseph, plaintiff, pro se, in the above entitled action, hereby declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection:

l. On or about June 20, l988, at approximately 2:00 a.m., on the southwest sidewalk of Lafayette Park, at a demonstration site that I, Philip Joseph, have maintained 24 hours a day since September, l986, Officer Tim Waite of the U.S. Park Police ap-proached me and asked if I had registration on a ten-speed bicycle that was present at my signs.

2. I replied, "No," and that "a fellow officer from the USPP had informed me two days ago that I had l4 days to register the bicycle."

3. Officer Waite then asked me for identification.

4. I replied, "I have no identification." Officer Waite left.

5. Approximately twenty minutes later, at about 2:20 a.m., Officer Waite returned on foot while a solid white USPP vehicle pulled up beside my demonstration on the street. Inside was an unidentified lieutenant.

6. Officer Waite then said, "Would you like to unlock the bike? Or I'll cut the lock off."

7. I stood and asked, "What's going on? Why are you wanting to take the bike?"

8. Officer Waite said, "Because of no registration and because you have no I.D. or proof of ownership."

9. I walked to the lieutenant in the car in an attempt to reason with him. I told the lieutenant that "I had put the bike together out of trashed parts from five or six different bicycles, and that two days prior an officer from USPP had told me I had l4 days to register the bike, which means I still have l2 days to register it."

l0. The lieutenant said, "That's not true, you don't have l4 days and you don't have any I.D."

ll. I said, "The USPP and DOI know who I am, I've been arrested numerous times by USPP and every day for l-l/2 years you ask me my name for demonstration activities. You also have ticketed me for camping in Lafayette Park which resulted in two months imprisonment. Your own records of demonstration activities show who I am. Above all, I would like a couple of days to get the bike registered."

l2. The lieutenant replied, "I don't know who you are."

l3. I said, "I am Philip Joseph."

l4. The lieutenant replied, "I said I don't know you and you don't have a couple of days to register the bike."

l5. I asked the lieutenant, "Is Officer Waite going to take the bike and does he have a right to?"

l6. The lieutenant replied, "Yes."

l7. I turned back to Officer Waite and said, "Here, I'll unlock it for you, you don't have to cut the lock, I'll give it to you."

l8. I unlocked the chain-combination lock from the bicycle and pulled the lock from the bicycle.

l9. As soon as I loosed the lock Officer Waite jerked backwards on the bicycle, causing the handlebars to catch my leg, which wedged in between the handlebars.

20. I said loudly enough to be heard, "Wait," but he kept pulling backwards with my leg caught in the handlebars.

2l. I then turned my head back towards Officer Waite, at which time he grabbed my right hand and twisted it, pulled me back towards him and pushed me on top of the bicycle.

22. While twisting my arm he pushed me to the grass and on top of the bike; he then rolled me to the side of the bike, onto my stomach, while he proceeded to handcuff me.

23. Officer Waite squeezed the cuffs so tight that they cut both wrists with small lacerations. I requested that they be loosened and he did not reply.

24. He then jerked me up from the ground to my feet by using my hands, which were cuffed.

25. Then, while moving me toward the sidewalk, Officer Waite kicked me in the back with his knee. I said, "Stop kicking me, Waite." He said nothing.

26. Officer Waite never said a word while he pushed me across the sidewalk to a patrol car.

27. I asked, "Why are you doing this to me?"

28. Officer Waite pushed me towards the car and said, "Disorderly conduct."

29. I was then transported to Haines Point USPP substation, where it took Officer Covington several minutes to remove the handcuffs, which were so tight they wouldn't release.

30. The next day, in D.C. Superior Court, I was told by the Commissioner, "Your case was not papered, you are free to go."

Written this 22nd day of June, l988,

Philip Joseph
P.O. Box 272l7, DC 20038
(202) 462-0757