Huddle, et. al.
             Plaintiffs pro se
                                         CA No. 88-3130
v.                                       Judge Joyce Hens Green

Reagan, et. al.


I, Albert Christopher Cole, hereby declare under penalty of perjury that the following is accurate and correct to the best of my knowledge and recollection.

1. Since January, 1991 I have been in Lafayette Park for the purpose of expressing opposition to war in the Persian Gulf. At times I have played drums in the park for the promotion of peace. On the 18th, however, I was not playing drums or much of anything because I had had a bad headache all day long.

2. On February 18, 1991, at approximately 7:00 PM, I was on the south sidewalk of Lafayette Park.

3. At about 7:00 PM, at the same time that T.V. news crews on the White House were preparing to begin broadcasting, Park Police Sgt. J.W Moore came onto the south sidewalk of Lafayette Park and informed a number of people who were beating rythms on plastic buckets that they were making too much noise.

4. One person (E.L.) asked Sgt. Moore whether he had taken a decibel reading. Sgt. Moore didn't answer the question, but stated that he was not giving a formal warning, only giving his opinion. E.L. said he didn't think that Sgt. Moore, who had been sitting in a closed car in the middle of Pennsylvania Ave., could have taken an accurate decibel reading, because to have taken a reading from the center of the street would have included the traffic noise. Sgt. Moore re-stated that he was not giving a formal warning, but that he was only "trying to be friendly."

5. There was some other conversation in which Sgt. Moore seemed to be more over-bearing than friendly, before he left the side walk and returned to his car.

6. Immediately after he returned to his car two Park Police officers approched Sgt. Moore's vehicle and engaged in conversation. Within minutes a Park Police paddywagon took up a position just to the west of the Park Police entrance gate in the newly erected chainlink fence on the south side of the park, and another Park Police cruiser took up a position approximately 35 feet to the east of the paddywagon. The driver of the cruiser read a warning about "drum-like devices" allegedly violating 36 CFR 2.12 and a D.C. statute.

7. I love the peacemaking power of the drums, and believe they are very important now. So, after the Park Police warned that people who were playing drums would be arrested if they did not cease, I assumed responsibility for three drums (actually plastic buckets, the police stole all the real drums a long time ago) which were laid down. I had stacked three buckets into one another and set then on the sidewalk right next to me.

8. When the Park Police began assaulting Jeremy further down the sidewalk, I picked up the buckets and hurried to that location to see what the police were doing.

9. Jeremy was handcuffed and on the sidewalk. Sgt. Meyers was kneeling on him.

10. A Park Police officer, who wasn't wearing a nametag, demanded that I give him the buckets I was holding.

11. I refused, told him that the buckets were mine and that I hadn't been playing drums.

12. The officer said that he wanted the buckets as evidence.

13. I pointed at the bucket which Jeremy had been playing, which was laying on the ground, and told the officer that that was his evidence.

14. The officer, with the assistance of another officer, forcibly took the buckets from my hands.

15. Although I asked him three times for his name, this officer refused to tell me his name.

16. The above related series of incidents, that I would call show harassment and theft, have become routine in Lafayette Park since about January 27, 1991.

17. On March 2, 1991 at approximately 3:30 PM on the south side of Lafayette Park, I was actively involved in the National Drum Day Rally, which started at approximately 3:00 PM.

18. A permit had been issued by the National Park Service for the National Drum Day Rally.

19. I was leaning over the newly installed fence at the curb, when I droppem my drum stick into the street. I then went to the gate, opened the gate, went out into the street, picked up the stick, returned throught the gate, and did not close the gate after I enterred the gate.

20. As I leaned over the fence and started to drum -again -- Lt. C.E. Clipper, badge # 938, Major (Holmsburg ?), and other officers came toward me. They grabbed me with a lot of force. Lt. Clipper and one of the other U.S. Park Police officers grabbed my arm very forcefully twisted my arms behind my back,. These officers were very harshly pushing me into the street, across the street, into the median in the middle of the 1600 block of Pennsylvania Avenue N.W.

21. At the same time there was a U.S. Park Police transport truck or wagon parked next to the unmarked all white U.S. Park Police officers car. As Lt. Clipper slammed my head into the hood of the car, someone else handcufffed me very tight and was pulling on the cuffs, forcing my arms higher and harder up my back.

22. While my head was on the hood of the white car the Major pushed the drum stick into my mouth.

23. Lt. Clipper lifted my head and turned me around and slammed me into the side of the police three times, and still pushing my cuffed hands up my back.

24. At this time he was causing great pain the the front of my shoulder. Now after this there are two other officers, I could not see name tags, hitting me about my upper body and right thigh with something I could not see. One of the black officers grabbed my face and told me that I pressed my luck last week and that I asked for it. they dragged me forcefully by my arms to the back of the wagon and three officers lifted me up and threw me into the prisoner compartment of the wagon. This hurt the left side of my face even more.

25. After a few minutes I noticed the police throw Darin into the other side of the prisoner compartment.

26. She asked me if I was alright and I said my face, shoulder and leg hurt. She screamed for the officers in the front to call for an ambulance. They owuld not call one or answer Karin.

27. On arrival at Anacostia station the driver grabbed my legs and pulled me out of the rear of the vehicle by my legs. Another gentleman in civiliam clothes helped him.

28. I told him of the severe pain in my shoulder and he still grabbed my arms.

29. I walked into the station after they got me out. As we arrived in the station I informed everyone the extent of pain and to please call 911 for an ambulance. they told me I did not look hurt, and did not call for one immediately. So a few minutes latter I kicked the door of the cell, asking to please call for an ambulance.

30. A detective came in and was persistent on asking what was hurting. After I had said several time, my shoulder, face and leg hurt. He said that the way I was acting it didn't seem like I need an ambulance.

31. Without any provocation, another officer, wearing a blue T-shirt, who was about 6'3" about 320 pounds, grabbed me, hit me several times, causing more pain to my right shoulder. He then threw me to the floor, put leg cuffs or ankle cuffs on me and walked out.

32. Then the detective came back in and said he had called for an ambulance. When they arrived I was taken to the D.C. General Hospital at 5:00 AM.

33. I was not seen by a doctor at the hospital until approximately 12:00 mightnight.

34. The police released Karin on a Citation Violation Notice. Although they knew who I was, and although I had the same charges as Karin, after I left the hospital the police took me to the Central Cell Block.

35. I spent a very unwarranted, uncomfortable, hungry two days in Central Cell Block before being finally taken to court, where all the charges against me were dropped.

Under penalty of perjury,
March __, 1991,

/s/ Albert c. Cole
Albert Christopher Cole
1610 Trinidad Avenue, N.E.
Washington, D.C. 20002

Declaration: Brian Barrett