Huddle, et. al. ) Plaintiffs pro se ) C.A. No. 88-3130 ) v. ) Judge Joyce Hens Green ) Reagan, et. al. ) Defendants. ) __________________________________)
I, William Thomas, hereby declare under penalty of perjury that the following is accurate and correct to the best of my knowledge and recollection.
1. As may be evident from my cameraship, I had no prior experience with video documention before this tape.
2. I submit the attached video tape (Exhibit A) because I believe the sign segment demonstrates that:
a) between January 24th and March, 1991 numerous Park Police agents seized, or attempted to seize, signs from plaintiffs;
b) between January 24th and March, 1991 numerous Park Police agents threatened to seize, or seized, plaintiffs' literature, or threatened to arrest plaintiffs because of their possession of literature;
c) plaintiffs have requested that defendants or their agents specify the precise object or nature of conditions which defendants have alleged to be in violation of regulations, to enable plaintiffs to comport their presence and activities to the regulations. Defendants have refused to provide the specific information.
3. I submit the attached video tape because I believe the
"camping" segment shows that:
a) defendants recognize that there are "problems," and have advised plaintiffs to "take it to court;"
b) defendants knew a "vigil" was legal, "no question about it;"
c) what plaintiffs intend to be a "vigil," defendants arbitrarily define as "camping;"
d) between February 3rd and March 5, 1991, defendants, in the person of Sgt. Rule, altered the definitive element of "camping" from "two hours of sleep," to "less than two hours of sleep," to "sitting on bedding," until Concepcion was eventually threatened with arrest while only sitting on a piece of cardboard;
e) plaintiffs have repeatedly been threatened with arrest. One plaintiff and others have actually been arrested under color of "camping," according to Sgt. Rule's changing definitions;
f) the tape records Sgt. Rule admitting collaboration with defendant Robbins in "camping" regulation enforcement;
4. I proffer this video tape because I believe that the "force and violence" segment of the tape illustrates:
a) Park Police agents have used excessive force to disrupt peaceful, law-abiding assemblies;
b) plaintiffs have suffered, and are in danger of suffering, physical injury as a result of the use of excessive force in the disruption of peaceful, law-abiding assemblies.
c) defendants actions have had a chilling effect on the exercise of First Amendment rights by plaintiffs and others.
5. I also think that the violence segment of the tape shows
that defendants have disrupted legitimate demonstration activities with no intent to further any legitimate interest.
6. What defendants have described as a "game," has actually been a concerted effort to stifle opposition to administrative policy. See also Declarations of Allen Tubis (para. 18), Karin Love Cartright (para. 36), and William Thomas in support of the Complaint (paras. 60, 61).
Respectfully submitted this __th day of March, 1991,
William Thomas, pro se
2817 11th Street, N.W.
Washington, D.C. 20001