UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MARY HUDDLE, et al.
v. Civil Action No. 88-3130
Judge Joyce Hens Green
RONALD WILSON REAGAN, et al.
DECLARATION OF CONCEPCION PICCIOTTO IN SUPPORT OF
PLAINTIFFS' MOTION FOR A PRELIMINARY INJUNCTION
TO STAY CRIMINAL PROSECUTION
I, Concepcion Picciotto, hereby declare under penalty of
perjury that the following is true and accurate to the best of
my knowledge and recollection:
1. On June 1, 1990 at approximately 1:30 PM I was at my
demonstration site -- consisting of two signs, two flags, and
literature -- on the south side of Lafayette Park, facing the
2. Approximately forty feet to the northwest, and in plain
sight from my demonstration, a man had tied two flags and a sign
to a park bench.
3. U.S. Park Police Officer Joyner approached me and ordered
me to take down my two flags.
4. I asked Officer Joyner, "Why?" He replied,
"It's the law." I asked him to show me the law in writing.
5. Officer Joyner Just put my two flags on the ground.
Officer Joyner did nothing about the two flags and the sign tied
to the park bench.
6. After the officer left, I put my flags back.
7. Later, at approximately 3:00 PM there was a large number
of Park Police officers in front of my signs waiting for Mr. Gorbachev
to arrive, and various small groups of demonstrators crying "Democracy,
- 1 -
8. Several Park Police officers approached my demonstration,
and ordered me to put my flags down, telling me that I was in
violation of the law. Approximately forty feet to the northwest,
and in plain sight from my demonstration, the two flags and sign
were still tied to the same park bench. The man who had tied them
there was nowhere in sight.
9. I was told, "Do as we say or we will take them
10. When I made no move, Officer Joyner threw my flags
down on the ground.
11. My colleague, William Thomas, who arrived at my demonstration
at about that time, put the flags back up.
12. On June 13, 1990, at approximately 8:30 several U.S.
Park Police vehicles began to congregate on Pennsylvania Avenue
in front of my demonstration site.
13. About half a dozen U.S. Park Police officers, led by
Sergeant Gentile, approached me and I was told to A put my flags
14. When I asked why, I was first told that the flags could
not be attached to my signs.
15. I pointed out that the flags were not attached to the
signs, but only resting on them.
16. I was told that they couldn't be resting on the signs.
17. I offered to put the flags in separate stands instead
of resting them on the signs.
18. I was told that I would have to put them down.
19. I asked what I could do to satisify the police that
my flags weren't violating anything. I was again told to take
my flags down or the police would do it.
19. When I made no move to take the flags down, two officers
each took one flag and put them both into a paddywagon.
20. I was issued National Park Service United States District
Court Violation Notice P-192081 by Park Police Officer Bacon,
whose "Offense Description" read "Sign violation
(above six feet in height)."
Under penalty of perjury
/s/ Concepcion Picciotto