UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MARY HUDDLE, et al.
v. Civil Action No. 88-3130
RONALD WILSON REAGAN, et al.
DECLARATION OF SCOTT DAHL
I, Scott Dahl, pursuant to 28 U.S.C. § 1746, depose
and say as follows:
1. I am an officer of the United States Park Police, assigned
to the Central District Substation.
2. On the late evening of November 10, 1989, I was assigned
to a foot patrol in Lafayette Park.
3. Shortly after 10:00 p.m., as part of my official duties,
I began my patrol. My sole purpose in Lafayette Park was to ensure
compliance with applicable Federal statutes and/or regulations.
On the southeast area of Lafayette Park, I observed Joe Vigorito
lying in a sleeping bag. I told him of the camping regulation
and took him and his belongings to the adjacent sidewalk. At that
point, he became loud and abusive and shouted obscenities to me.
4. I then walked over to the southeast sidewalk of Lafayette
Park where I observed two wooden signs placed approximately six
feet apart. Attached to the signs was a large plastic tarp which
completely covered the area between the signs and to the ground-on
each open side. At that time, I could not see anyone inside. I
identified myself and asked if anyone was inside the structure.
There was no response and I took one side of the plastic tarp
and pulled it up and saw Jeffrey Brown lying inside and under
blankets. I told Mr. Brown that he could not have the plastic
tarp draped over the signs to form a structure. Mr. Brown stated
to me that no law prohibited the plastic. I stated that plastic
tarp was permitted as long as it did not form a structure.
5. I then left and checked the other sites in Lafayette
6. When I returned to the southeast area of Lafayette Park,
I observed Joe Vigorito. He was again in his sleeping bag. I informed
him again of the camping regulation and took him and his belongings
to the adjacent sidewalk. At that point, he again, became loud
and abusive and shouted obscenities to me.
7. I then left and went to the southeast sidewalk of Lafayette
Park where I observed the plastic tarp was now covering Mr. Brown
and all of his belongings, but it was not draped over the signs.
I told him, that the tarp could not cover him to form a structure
but could only cover his belongings. I then grasped the tarp which
was covering him. He began to struggle for it and I let go of
the tarp. At that time, Mr. Brown got up and became agitated,
abusive and yelled obscenities at me. In an agitated state, he
then took a step towards me. I took out my nightstick and told
him if he came at me I would hit him. Mr. Brown did not come closer
though he continued to be verbally abusive.
8. At that time, with Mr. Brown still being abusive to
me, several other people approached me in what appeared to be
in an agitated state. With my nightstick still out, I told them
to stay clear. Several officer" of the Secret Service Uniform
Division apparently saw the situation where was by myself and
came across Pennsylvania Avenue to my assistance. The others then
became calmer and went back to their demonstration sites and the
Secret Service officers returned to their duty station at the
9. I then walked to the center of the southside sidewalk.
I was approached by two individuals whom I had never seen before.
Mr. Brown at his site was still uttering obscenities. The two
individuals asked why I put up with these obscenities. I explained
that police officers had to accept obscenities as part of the
job. The two individuals then began yelling at Mr. Brown and the
other demonstrators. I then told the two to calm down and to stop
yelling. Shortly thereafter, the two left, walking eastbound past
Mr. Brown. I stayed at my location to make sure there would be
no disturbance between them. When the two left Lafayette Park,
I then walked westbound on the sidewalk and radioed for my superior
to inform her of the incidents.
10. Sgt. Gonzales appeared and I told her what happened.
Mr. Brown approached and talked with my supervisor. Afterwards,
Sgt. Gonzalez assigned Officer Joyner to accompany me
for the rest of my tour in case there were further incidents.
11. After approximately a half hour, Officer Joyner and
myself went through Lafayette Park. I observed, again, Mr. Vigorito
lying in a sleeping bag. I again informed him of the camping regulation
and, again, took him and his belongings to the adjacent sidewalk.
Again, he became loud and abusive and shouted obscenities.
12. I then went to the southeast sidewalk and observed
Mr. Brown awake and that the tarp was not covering him. Mr. Brown
then asked me why did I not get a real job. I responded: me get
a job? You are one to talk -- you are supposed to be demonstrating
not just lying around, or are you too lazy to get a job? Officer
Joyner and I then walked away from Mr. Brown.
13. As we walked away Stacey Davis, who was sitting nearby,
complained about the yelling which occurred earlier I told her
that I never yelled anything to Mr. Brown or Mr. Vigorito or the
others, but it was the other two men who were yelling. She disagreed.
I stated to her that it was her opinion.
14. As Officer Joyner and I continued to walk down to the
southwest corner of Lafayette Park, we were approached by Mr.
Cronin. In an angry tone he asked me what I had said to Mr. Brown.
I said that what I told Mr. Brown was none of his business.
15. Mr. Cronin and I exchanged further words and as I started
to walk away, Officer Joyner walked in front of Mr. Cronin to
prevent him from following me. At that time, Officer Joyner had
his flashlight out at chest level and told Mr. Cronin
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to stand back. Mr. Cronin kept approaching Officer Joyner and
walked into the flashlight the officer was carrying. Officer Joyner
then, again, instructed him to stand back.
15. Mr. Cronin stated that he would continue to follow
us and began to berate us. I then told him that we were going
to walk north through the Park. Mr. Cronin then stated that he
would not follow us into the darken area because we would probably
beat him up.
16. Officer Joyner and I continued our patrol of Lafayette
Park. At around 5:45 a.m. Officer Joyner returned to the Substation
and I did my final tour of Lafayette Park. At that time, I observed
Mr. Cronin and Mr. Davis asleep. I tapped on their sign which
woke them up. I inquired if they were okey, or awake and asked
Ms. Davis her name. She refused to identify herself.
17. Shortly thereafter, my tour ended and I left Lafayette
18. I here attach the reports I completed concerning the
incidents discussed herein.
19. At no time did I give "lecherous stares"
to Ms. Davis. At no time did I assault anyone.
20. I have never attempted to deprive Jeffrey Brown, Michael
Cronin, Stacey Davis, or any of the plaintiffs of their civil,
or constitutional rights.
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21. I have never conspired with anyone to deprive Jeffrey
Brown, Michael Cronin, Stacey Davis, or any of the plaintiffs,
of their civil or constitutional rights and I am not aware of
anyone else having ever done no.
22. I have never "harassed" nor "intimidate"
Jeffrey Brown, Michael Cronin, Stacey Davis, or any of the plaintiffs,
because of content of their signs, or because of any political,
or other viewpoint they espouse. I have investigated demonstration
sites on National Park Service property solely to determine if
violations of Federal statutes and/or regulations were occurring.
I declare under penalty of perjury that the foregoing is
true and correct to the best of my knowledge and belief. Executed
this 30 day of November, 1989.
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//s// Scott Dahl