This is an account of incidents witnessed in Lafayette Park (Washington, DC) between about 7:15-8:00 pm on Sunday, February 24, 1991.

Incident #1

The police were arresting people who were protesting for peace in the park. I did not see anyone resisting arrest.

About 10-15 feet away from the park side of the fence, I saw an officer twice hit a person who was lying on the ground. This person was lying on his/her side with knees tucked up toward the chest (like a fetal position) and arms wrapped around the upper body as if this protect him/herself. The person was facing away from the officer.

The officer used a billy club to strike the person. The person did not move while lying on the ground, displayed no weapons, did not attempt to escape, and made no attempt (either before or after the blows) to strike back at the officer. The officer clearly was not in danger.

I witnessed the officer raise his arm with the club and strike the person on the side at about the waist. The officer struck the person again in a similar fashion about seconds later.

Then, another officer came and together both officers dragged the person across the sidewalk and through the fence gate where police vehicles where parked in the street.

Incident #2

A police vehicle (#W-5) was parked on the street about 18"-24" from the park's fence. I noticed 2 officers standing between the vehicle and the fence in that narrow space. They were observing the events in the park.

They stood there for about 5 minutes, and during that period I saw both of them kick something on the ground, as if they were trying to kick something out of their way toward the fence.

At first, I thought that they were just clearing out the narrow space between the vehicle and the fence, maybe pushing away some of the plastic buckets that the police had confiscated so that they would have more room to stand. However, I moved closer to get a clear look and saw a person's legs at the officers' feet, protruding from that narrow space.

The person was lying on the ground in between the vehicle and the fence. He/she did not move, made no attempt to escape, did not appear armed with a weapon and did not attempt this strike at the officers. The officers clearly were not in danger from this person.

The officers were standing next to the person looking away at the park, and would randomly turn and kick the person into the fence, sometimes one, sometimes the other and sometimes both together. I saw the person be kicked by the officers about 5 times.

I submit this account of these incidents as true events that I witnessed at the time and place stated above.

Beverly Jeanne Chagon (SSN 041-38-6762)
7417 Holly Ave., Takoma Park, MD 20912

Exhibit 11- L