PLAINTIFF'S EXHIBIT 11- F
Sworn Statement of Timothy P. Keenan.
I, Timothy P. Keenan, swear to the following description of the events as I observed them on the evening of Sunday 24 February 1991 at Lafayette Park, on the 1600 block of Pennsylvania Avenue, Washington, District of Columbia.
I arrived at Lafayette Park shortly before 7pm and observed a peaceful, nonviolent demonstration against the war in the Persian Gulf. There were a circle of people surrounding those individuals who were beating the the plastic pails, the drum of the urban instrumentalist. The number of those still drumming by the time 7pm approached was small. The human circle surrounding them made it difficult to see exactly how many but there were approximately 3 -5 people playing at that time.
The volume of the drumming was far from overpowering. I had walked to the Park, coming south on 16th Street. It was not till I was within a block of the Park that I could here the drumming at a11. At no time while at the Park did I find the volume of the drumming offensive.
When I reached the Park, I went to its southern border at Pennsylvania Avenue to be close to the drummers and observe the blockade of Police and Park Police vehicles stretching the length of the meridian on Pennsylvania Avenue. I was standing near the chain link fence which has been erected along the edge of the sidewalk at the Park. The drummers were northwest of me. One of the officers started making and announcement which was quite hard to hear even through he was only a short distance away. I was probably closer to the officer making the announcement than drummers. I could only decipher certain isolated phrases, such as "it is now 7pm", "and sound ordinances."
Very shortly after the officer stopped his announcement, the Park Police, without further warning or provocation, attacked from two sides the drummers and the circle of people surrounding them. The attack came in the form of two single file columns of officers driving viciously into the circle of people. Once the officers smashed through the circle of people, they started randomly dragging people along the ground to which they had been knocked by the offices, over the concrete walkway towards fence, where they were arrested. The situation was very chaotic, and further complicated by the presence of the mounted Police.
I turned around toward 16th street again to see a person pinned between the chain link fence and a Police Paddy Wagon. This person was doubled over with one hand attempting to cover his or her head. An officer was directly in front of the person and was searching with one had for something near his leg. A second officer was standing about two feet behind this officer. The officer directly on front of the person found what he was looking for in about 30 seconds. It was his billy club and he proceeded to smash the person over the head a minimum of two or three times.
This appeared to be completely unnecessary. The person was already pinned between the fence and the Paddy Wagon. The officer was in no apparent danger and had a second officer there to assist him. The person made no threatening movements towards the officer at any time that I was allowed to observe. Very soon after the officer started beating the individual, I was forcibly moved from my position by officers in riot gear with their clubs drawn.
A very large semi-circle was formed around the area where the arrests were being made. The combination of the large distance and dark night made it very difficult to observe the actions of officers and those being taken into custody. The number of people arrested appeared to far outnumber those who were drumming. Thus it would seem there were many people falsely arrested.
The violence and belligerent attitude didn't stop here. Once the Police had sealed there perimeter one mounted officer turned his horse around and continually backed into the crowd. He claimed the horse was brand new and frightened, but the smile on his face while he was backing into the crowds, as well as the laughs of his fellow mounted officers, would belie his intent and purpose.
The presence of the mounted officers was hardly necessary. The number of people gathered at the Park could not possibly have been more than 150 or 200. There were no acts of aggression against the officers. Until the Park Police attacked, it was a very orderly crowd. I deeply disturbed by the number of officers present. It seemed to me the only purpose of the mounted officers was to intimidate those gathered at the Park.
/s/ Timothy P. Keenan
TIMOTHY P. KEENAN