MARY HUDDLE, et al. 

        v.                      Civil Action No. 88-3130

RONALD WILSON REAGAN, et al.            


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 Park.


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 White House.

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 Park.

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.

//s// Scott Dahl
Scott Dahl

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