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

I, Scott Michael Galindez, hereby declare under penalty of perjury that the following is accurate and correct: to the best of my knowledge and recollection.

1. On February 25, 1991, at approximately 7:00 AM, on a very cold day my sleeping bag was torn and its zipper broken off when a lot of police came into the park to wake people up. Video @ 58.25.

2. I believe that sleeping across the street from the White House is significantly symbolic and expressive and that such sleeping in public parks is protected under the First Amendment. Because I am maintaining my demonstration by myself, without assistance, it is impossible for me to maintain a long term presence without sleeping. I think it is more accurate to define my form of demonstration as a continuous presence rather than a vigil.

3. Over the years I have been known to maintain a sign that states, "I am not camping, I am demonstrating what the American People have been doing for the last # years, Sleeping." I have been cited for camping when I have had this sign.

4. For the reasons stated above I refuse to cooperate with police "wake up calls," and I don't respond. E.g. Video @ 50.18, 56.45, 57.14. In every instance shown on the videotape I am, however, awake when the police are shaking me and trying to get a response, refusing to cooperate with what I believe is an unjust law.

5. On March 1, 1991 I heard Sgt. Rule say that merely sitting on a blanket was a violation of the camping regulation. Video @ 107.39. Again, wishing to demonstrate my refusal to cooperate with what I consider to be an unjust law, I immediately got into my sleeping bag, and lay on the sidewalk. Video @ 101.50-105.50.

6. I was in my sleeping bag for no longer than twenty minutes, when I was arrested for camping. At no time did I sleep between Sgt. Rule's threat of arrest and my actual arrest.

7. I believe that my rights are violated whenever police officers harass me to see if I am asleep.

8. On January 15, 1991 at approximately 7:00 PM I was walking away from an anti-war picket when, speaking to fellow demonstrated Michael Beer, I made a comment about how warm it must be on the bus that the Park Police were using to keep comfortable during the demonstrations.

9. After I made my statement about the bus, Park Police Officer Long said, "What did you say Galindez?"

10. My reply was, "I wasn't talking to you."

11. Officer Long then replied, "I'll get you Galindez." Officer Joyner was standing next to Officer Long, swinging his club in the air and hitting his hand.

12. I didn't see Officer Long and Joyner again until January 19, 1991, when I was witnessing the arrest of four women who were blockading Pennsylvania Avenue.

13. Officer Long told me to move back away from the corner.

14. I responded by saying "hello" and "you are being much friendlier today."

15. He responded by saying, "Wait until later, I'll get you Galindez. This club is made just for you."

16. I complained to both Captain Irwin and Major Holmsburg about Long's threats, but over the weeks Long continued to threaten me.

17. On Saturday, February 14, 1991, while I was having an argument with an officer about the sixty decibel sound limit, Officer Long told me to go away and stay away or he would arrest me.

18. When I asked him why, he told me that since he had been told to stay away from me by Capt. Irwin, I had to stay away from him.

19. I had no more major meetings with Officer Long or Joyner until February 23, 1991, the night the ground war began in Kuwait.

20. I witnessed Joyner and Long arrest Allen Benson for tying a ribbon on the chain link fence that separates Lafayette (Peace) Park from Pennsylvania Avenue. They held him with chest on the top of the fence, while Officer Joyner pulled on Allen's hair.

21. The effect of the hair pulling was that it lifted him off the ground, putting his weight on his chest, which was resting on the top of the fence.

22. A few minutes later they arrested me for drumming.

23. When the officer in charge pointed at me and told Long to arrest me, Long said, "Galindez, good, you're going to my house now, Galindez."

24. As soon as they got me to the other side of the paddy wagon they started slamming me repeatedly against the side of the wagon. They then started accusing me of kicking them, calling them names in an attempt to scare me into thinking they were going to rough me up.

25. While I was in the paddy wagon officers Long and Joyner arrested two more demonstraters, Song and Diana.

26. Diana was in a lot of pain when she got into the wagon. In fact she was doubled over. She explained to us that she was carried by her handcuffs to the wagon.

27. Four people were arrested and all were arrested by Long and Joyner, even though at least fifteen Officers were on hand.

28. When we got to Anacostia Park Police headquarters, Diana was the first taken out of the paddy wagon, followed by Song, who upon stepping down, was thrown to the ground.

29. The door of the wagon closed and all I could see was Songs legs on the ground. I heard Diana screaming, "You're hurting him!" but I couldn't see what was going or.

30. I next saw Officer Long on February 26, 1991 at approximately 10:30 PM. On that occasion I began chanting about five feet behind a television crew on the north side of Lafayette Park.

31. I noticed a Park Police vehicle pull into the park, I began walking away.

32. Officer Long then called me over to him. I walked over and he shouted at me, telling me to leave the media alone.

33. I responded by saying that I have the right to say what I want to say, when I want to say it. I was pointing at Officer Long during my response.

34. Officer Long then grabbed me by my jacket collar, and placed his leg behind me and pushed me down, shouting, "Don't you ever point at me."

35. I curled up like a turtle and Officer Long began grabbing at me. I kept stating that I was non-violent. He finally backed off, and when I got up I noticed another demonstrated arriving from the south side of the park.

36. Four days later, after what he claimed was 35 minutes of observation by him of me wrapped in a blanket, at 6:00 AM Officer Long arrested me for camping.

37. At approximately 8:50 AM on March 12, 1991, when we both arrived to testify at a Grand Jury inquiry, Officer Joyner said to me, in front of Judiciary Square 555 4^th Street, N.W., "People like you don't live for long. Somebody will get you someday."

38. At approximately 12:30 PM, on our way out of Judiciary Square, I asked Officer Joyner if he would like to repeat what he had said earlier in front of the U.S. Attorney. His response was, "Down here all you are is an unfortunate sperm."

39. During my booking in Anacostia on February 27, 1991, after a charge of audio disturbance, I cooperated in every way. I was not asked my name by the desk officer or the arresting officer. When I first arrived the desk officer asked me my birthday and place, but not my name. She told me that was all she needed. They fingerprinted me and took my picture. They asked me my social security number and address, but never my name, but from the point of arrest the officers called me "Scott" or "Galindez." They didn't ask me for I.D. until after all the paper work was finished.

40. "Judy," the desk officer who booked me without asking my name, said, "No I.D. means Central Cell Block."

41. I was arrested, booked and sent to Central Cell Block, although the police know who I am, and should have released me on a Citation Violation Notice.

42. On March 2, 1991, "National Peace Drum Day," I went with Wally Brown and another friend, Beth, to Anacostia substation to pick up Karin Cartright and Albert Cole, two demonstrators who were arrested earlier in the day.

43. As we approached in Beth's car we noticed an ambulance (license # Amb-7) in the parking lot of the substation.

44. We exited the car at 5:30 PM and started walking toward the front door of the station.

45. We were halted by Park Police officers, one a detective and another Officer Jones #345.

46. We then noticed Albert Cole being escorted out the front door with his arm in a sling. He was walking slowly and looked like he was in pain. The first and only thing he said was, "They beat the shit out of me."

47. Al was put in the ambulance.

48. The detective said that Beth could go in and told Wally and me to stay around the car.

49. Beth went inside and we went to the car. I began taking notes and decided to talk to the ambulance driver and find out how Al was, and to get his last name.

50. Before I could find the driver Officer Dahl threw me against a car and twisted my arm behind my back.

51. I told him I just wanted to talk to the driver and he responded by saying, "You can get away with that shit in the park, but not here."

52. I then called Major Holmsburg over and told him what happened. He shrugged his shoulders and told us that "they were only treating you the way you wanted to be treated."

53. On Sunday, February 24, 1991 the Washington Area Coalition to Stop U.S. Intervention in the Middle East held a demonstration that started at 5:00 PM in Lafayette (Peace) Park.

54. After a rally that included speakers and amplified music the organizers decided to join the Peace Park Antinuclear Vigil for a drum circle.

55. At approximately 7:00 PM the United States Park Police sent dozens of officers into the park wearing riot gear. At that moment there were twelve people drumming. Fearing an attack on the drummers, other demonstrators, trained in non-violence, formed a human chain around the drummers and began chanting "1-2-3-4 we don't want your bloody war, 5-6-7-8 we will not cooperate." Video @ 29.18-45.00.

55. On the south side of the circle a dozen officers lined up. About the same number of officers lined up on the north side of the peaceful drum circle. On the east and west sides police on horses lined up.

56. At approximately 7:10 PM I overheard Lt. Melenson tell a Park Police Sergeant "We will have to break through." Video @ 32.10.

57. I heard the police warn the drummers about arrest, but I did not hear anyone warn the people on the human chain about arrest.

58. The police charged the chain, holding clubs out in front of them of them. What followed was total madness, the police throwing people around, swinging clubs, dragging people around, the horses moving in on the sides where people were trying to escape the police.

59. People ran out of the park to go home.

60. The police couldn't have done a better job of discouraging people from returning to Lafayette Park.

Under penalty of perjury,

Scott Michael Galindez
P.O. Box 27217
Washington, D.C. 20038
462-0757