UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MARY HUDDLE and
PHILIP JOSEPH, et. al.,
Plaintiffs, Pro Se
versus CA 88-3130-JHG
Judge Joyce Hens Green
RONALD WILSON REAGAN, et. al.,
DECLARATION OF STACEY DAVIS
I, Stacey Davis, hereby declare under penalty of perjury
that the folliwng is true and correct to the best of my knowledge
1. I, Stacey Davis, a vigiler at Peace Park, on October
30, 1989 did overhear and later join the argument between Nakita
(Jeffrey Brown) and Officer Marsh.
2. The officer was telling Nakita that he must take off
the plastic he had over himself and his literature, to protect
him from the rain. Marsh stated, "How will I know what you're
doing under that plastic?"
3. Nakita said, to the effect, that the law allows for
covering with plastic during inclement weather. At that point
I felt the conversation would end with an apology from Officer
Marsh and a "have a good night" from Nakita.
4. However, as the officer continued his objection to Nakita's
plastic, they were joined by Michael Cronin, Rick Hartshorn, and
Joseph Vigorito, concerned vigilers.
5. Michael stated that the regulation was in violation
of a citizen's rights as granted under the Constitution, and as
he began to speak of those Constitutional rights, Officer Marsh
told Michael "not to talk to him about that."
6. Michael and the other vigilers continued to explain
their cause and rights to peaceful assembly granted under the
amendments to the Constitution.
7. It was then that I heard Officer Marsh say to Michael,
"When I'm in this park, you will do what I tell you to do."
He was pointing his finger in Michael's face.
8. I feel it is important to point out that at this time
I was still at my demonstration site, which is approximately 20
feet away from where the argument was taking place.
9. Officer Marsh was becoming very loud and, at one point,
threateningly so. Soon after that, I heard him say, again in quite
a loud tone, "I'll just quit my job, take off this badge,
and kick off on yo' ass."
10. I might also add that, from where I was seated, his
voice was the only one clearly audible
11. I entered the argument after Officer Marsh got back
on his bike, while Michael and the others still continued to try
and reason with him. He just sat there and laughed, as if the
fact that he did not understand the concept of "certain inalienable
rights" was humorous.
12. I told him he was not the one who should be laughing.
We demonstrators, here at the vigil for peace, do not find it
even slightly amusing that every day and every night we are threatened
by the ignorance of the people who are sworn to uphold the Constitution,
which was designed to protect us.
13. He finally left, saying he could look under the plastic
if he wished. No real agreement was reached. Marsh would not compromise,
except to agree that the plastic could cover an individual to
avoid inclement weather, but that if he rode by and called out
to an individual who was under plastic they should show themselves
as being neither sleeping, suffocating, or conducting any other
act that would be "in violation of 36 CFR
14. At exactly midnight and on until about 5:00 AM of November
10, 1989, I was witness to and victim of the continuing harassment
and actions of one Officer Dahl, another Park Police officer.
Officer Dahl was arguing with Nakita about the plastic which he
had over him only up to his shoulders.
15. This argument was soon joined by Joseph Vigorito and
Michael Cronin in support of Nakita's argument.
16. Officer Dahl had tried to rip the plastic off of Nakita,
giving no reason other than he didn't "want it there."
Soon, reaching no agreement and giving no reasons to justify his
actions, Dahl stormed off on foot.
17. Not very long after that a shouting match began between
Dahl and Nakita. Dahl was now standing a little more than halfway
down the block yelling "FUCK YOU, PUSSY" and Nakita
was yelling back, "Come back down here, Dahl." Two apparently
drunk guys seemed to be amused at this shouting match and they
started yelling, "Yeah, F*** you, you pussy!"
18. Dahl did nothing to discourage them so they walked
down past Dahl and started threatening Nakita and Michael. I asked
who they were and the man who said "I'll kick your ass"
to Nakita then turned to me and said, "I'm a police officer,
19. I had no reason not to believe him, because Dahl is
a police officer and these two drunk men were talking and behaving
just as Dahl was.
20. About half an hour later, my attention was again directed
to Nakita's site where Officer Dahl and another officer who refused
to give his name were once again harassing Nakita. What caught
my attention first this time was that Dahl was yelling at Nakita,
"I don't give a shit about you and your f***ing demonstration.
The only reason you're out here is because you're too f***ing
lazy to get a job' you bum!"
21. Nakita started to say something back, using a few curse
words of his own! when the officer who refused to identify himself
threatened Nakita with arrest for using vulgarity. They
soon started to walk away, still not reaching any sort of agreement
with Nakita, and as they passed by my demonstration site I said
to Officer Dahl, "The only reason your officer friend could
even arrest Nakita for vulgarity is because he has the nerve to
say it to your face, unlike you, who has to yell obscenities from
half a block away!" He only replied with, "No, ma'am,
I don't think so" and "That's just your opinion"
and "You're lying, you little smartmouth."
22. Michael followed them down the block and then came
back. We settled down for a while.
23. One more time, at about 4:30 or 5:00 that morning,
Dahl returned, kicking on the back of the sign and laughing and
saying he didn't kick the sign. He leaned over the top, leering
down and saying, "Well, now, don't we look like the cozy
little couple." I looked up at him once and then ignored
him, as he was trying to get my attention by saying, "Ma'am,
what is your name?"
24. Michael told him that he asked me that the last time
he was on duty, so it must be on his books. But Dahl said he know
that, but he didn't have his record with him. So he kept asking
and asked if I was all right. I was ignoring him because the lecherous
stares he directs at me make me sick. Michael told him I was all
right. Dahl kept saying, "But I want to hear it from her."
Finally Dahl left.
25. Although Dahl was rude and abusively threatening to
other vigilers he came in contact with that night, he seemed to
hold a special look and attitude toward me that seemed both lecherous
and possessive. Even when he talked to other people, he would
look at me, even when I'm not saying anything at all.
26. Joe Vigorito walked behind Dahl as he left and Dahl
turned around and told Joe that he hadn't given him permission
to follow him, and that Joe had "better stop following"
him. But finally Dahl left, as promised Joe "escorted"
Dahl through the vigil, and no more trouble was started that early
Under penalty of perjury,
//s// Stacey P. Davis
Washington, D.C. 20038