MARY HUDDLE and PHILIP JOSEPH, et. al., ) ) AND ) ) CONCEPCION PICCIOTTO, pro se ) P.O. Box 4951 ) CA 88-3130-JHG Washington, DC 20008, ) Judge Joyce Hens Green plaintiffs, ) ) versus ) ) RONALD WILSON REAGAN, et. al., ) defendants ) ________________________________________)
I, Joseph Vigorito, hereby declare under penalty of perjury that the following is true and accurate to the best of my knowledge:
1. At approximately 12:15, on September 9, 1989, I was in Lafayette Park when I saw two oriental males, one carrying a video camera, the other carrying the video power pack.
2. Moving from east to west, the men proceeded past my position on the south sidewalk of Lafayette Park. Approximately fifty feet west of my position Concepcion Picciotto was standing between two signs which belong to her. Ms. Picciotto was addressing of group of 10-12 people who appeared to be tourists.
3. While Ms. Picciotto addressed this group the two oriental men stood a short distance away filming Concepcion's talk to the group of tourists.
4. After a couple of minutes the tourists left. The two men moved closer to Concepcion. A third oriental, a female, took the microphone and began to interview Concepcion.
5. For approximately ten minutes Park Police Officer Berkowitz had been sitting on a motorcycle under a tree approximately 25 feet away from Ms. Picciotto's signs.
6. Based on previous observation of Officer Berkowitz, it is my opinion that she has some personal animosity against the people who regularly demonstrate in Lafayette Park. Therefore I had been observing Berkowitz closely from the time she had pulled up to the area of Concepcion Picciotto's signs. Officer Berkowitz got off of her motorcycle and approached the group and began to speak to the people at Ms. Picciotto's signs.
7. From my vantage point I could not hear the conversation. There seemed to be some kind of disagreement. The reporters abruptly stopped filming, and immediately left the park.
Under penalty of perjury
P.O. Box 27217
Washington, D.C. 20038