UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Huddle, et. al.
            Plaintiffs pro se
                                      CA No. 88-3130
v.                                    Judge Joyce Hens Green

Reagan, et. al.
            Defendants.

DECLARATION OF BRIAN BARRETT

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

1. Because of the ongoing military conflict in the Persian Gulf, since December 8, l991, I have been spending an increasing amount of my time in Lafayette Park across the street from the White House in Washington, D.C.

2. Since this time I have witnessed and experienced what I can only describe as abusive police behavior, including assault, intimidation, and theft.

3. During the early morning hours of February 12, 1991, I was following Officer Watson and another officer, an AfroAmerican whose identity is unknown to me, through Lafayette Park. I was yelling with the intent to warn people that the police might accuse them of being in violation of a regulation if the police caught them asleep. At one point the unidentified officer said to me, "We know what you're doing. You're interfering with a police officer doing his duty. You've done it twice now already. If you do it once more you will be put under arrest." Video @ 49.20.

4. As I was being threatened by the black officer, Watson removed two blankets and a pair of white tennis shoes from a nearby bench. I informed Watson that the items belonged to Katie, a mildly retarted homeless woman, and pointed out where she was sitting - shoeless - with a group of vigilers. I knew she wasn't wearing her shoes because I'd advised her to put them on the night was cold - shortly before Watson and his accomplice began their rounds. Nonetheless, Watson declared that the articles were abandoned. Katie, in her stocking feet, ran up to Watson and asked for her belongings.

5. When Watson refused Katie's request, I protested that he had no grounds to take her blankets and shoes, not only on the moral grounds that he would be leaving her shoeless and blanketless on a very cold night, but also the legal grounds that she had identified the property as her own, and that she did not wish to relinquish possession of it. Ignoring our pleas, Watson disposed of Katie's possessions.

6. On Saturday, February 9, 1991, around 4 p.m., an officer whom I believe to be Lt. Clipper pulled a drum (bucket) from my hands. Almost immediately Sgt. P.F. Johnson grabbed me around the back/waist and threw me with such force that I hit the sidewalk some six to eight feet from where I'd been standing. My first view as I looked up from a supine position was of an officer moving at me, his right arm drawn back in striking position, a billy club clasped in his right hand. Fortunately, he reconsidered, and in moments I was on my feet. The officers surrounding me, including those aforementioned, began walking toward the chain link gate. Video @ 23.18.

7. My repeated demands to know why my drum was taken and why I'd been thrown to the ground were ignored until Lt. Clipper, now standing in front of the gate and facing me, stated, "Evidently there was a violation." He declined to respond when asked to identify the violation, which did not surprise me in the least. I had not committed any unlawful act.

Under penalty of perjury,

March _, 1991,
/s/Brian Barrett
Brian Barrett
2918 Meadow Lane
Falls Church, Virgina 22042
(703) 532-6378

Declaration: Brett Hamrick