USDC Cr. No. 84-3552

     Plaintiff Pro Se    
versus                          CA 84-3552
                                Judge Louis Oberdorfer
UNITED STATES, et al     

MARCH 20, 1987

I, Robert Dorrough, declare under penalty of perjury that the following is accurate and correct to the best of my knowledge:

1. At, or about 9:00 a.m. on March 20, 1987, while seated by my demonstration signs, I observed U.S. Park Police Lt. Hugh Irwin taking pictures of demonstration signs on the south side of Lafayette Park.

2. At about 9:05 a.m. I left the area to get some material which we had planned to use to fabricate a speaker's platform.

3. At about 9:15 I returned with three pieces of 1 x 6 boards, and a bag of tools. I set those materials down next to Ellen Thomas, and went over to the center of the park to set up the stage and public address system.

4. At about 9:20 a.m. I saw officer Hewick making off with the 1 x 6 boards which I had left next to Ellen Thomas, and was intending to use to mount the speakers for the permitted demonstration.

5. I left the stage at the center of the park and ran up to officer Hewick. I asked him what was happening. He told me to talk to Lt. Irwin.

6. I went over to where I had left my tools and material. Sgt. Moyer had my tools and was leaving in the direction of his vehicle. I told him that the tool bag was mine and that I would assume control. He and Lt. Irwin said it was being confiscated as abandoned property. I continued to ask for the return of my property as Lt. Irwin returned to his car.

7. At about 9:30 a.m. both William Thomas and myself were trying to reason with Lt. Irwin, explaining that we had a permit for a speaker's platform, when there was a disturbance at my signs.

8. Officer Hewick ran down the sidewalk to my demonstration site where I witnessed Sgt. Moyer striking and holding Scott Galindez, who had been watching my site. When officer Hewick applied his additional force, Sgt. Moyer slapped the handcuffs on Scott, and took him away, confiscating two smaller hand-held signs.

9. As a result of the actions of Lt. Irwin and his officers we were unable to construct the speaker's platform, and unable to conduct the demonstration as planned, and permitted.

10. At about 3:30 p.m. I observed Edwin Motley III parked in the area of the signs in a no parking, stopping or standing zone. Lt. Irwin drove up behind him, asked for registration and license, wrote him a ticket and told him to drive away. Mr. Motley drove a few feet before Lt. Irwin stopped him and had officer Ward arrest him for driving with an expired license.

11. At about 5:30 Edwin Motley returned to the Park on foot. Scott Galindez who had been arrested approximately six hours earlier was still no where in sight. Mr. Galindez did not return until after 7:30 p.m.

Sworn to this ____ day of March, 1987
Robert Dorrough

Case Listing --- Proposition One ---- Peace Park

_________________________________ Robert Dorrough