MARY HUDDLE and PHILIP JOSEPH, et. al., ) ) versus ) CA 88-3130-JHG ) Judge Joyce Hens Green RONALD WILSON REAGAN, et. al., ) defendants ) ________________________________________)
I, Concepcion Picciotto, plaintiff, pro se in the above entitled action, hereby declare under penalty of perjury that the following is true and accurate to the best of my knowledge:
1. Since April, 1986 my demonstration on the south side of Lafayette Park, in the 1600 block of Pennsylvania Avenue directly north of the White House, has included two signs and two flags.
2. At least as early as January 9, 1988 I began applying to the National Park Service for permits to conduct a demonstration in Lafayette Park. SEE, Exhibit A.
3. These permits were regularly renewed and granted.
4. Each of my permit applications stated that 2 signs and 2 flags would be among the props used in my demonstration. SEE, Exhibit B.
5. Both of the flags had a picture of a dove with an olive branch, and the words "White House Peace Vigil -- Since 1981."
6. On October 24, 1989, at approximately 4:30 PM I was at the center of my two anti-nuclear signs when I saw a Park Police cruiser, driven by Sgt. J. Paccione, park about twenty feet away from my demonstration.
7. Sgt. Paccione was joined by Officer Mitzell. They exchanged words, looking at my signs, and then they approached my demonstration site.
8. Addressing me they said that I must put my peace flags down for they were in violation of the law.
9. "What is the violation?" I asked.
10. Both officers said that I had four signs, not two, as "required" by "the regulations" (36 CFR 7.96 (g)(5)(x)(B)(2)).
11. Sgt. Paccione said that he had taken a photograph of my signs the day before, which he showed to his superiors, and they agree that I had four signs.
12. I told them that we had settled that in the past with Lt. Irwin. I told them that I had been given permits for my two flags.
13. Sgt. Paccione said, "Lt. Irwin is no longer here. I am in charge, and if you do not take them down we will do it."
14 I do not like to go to jail, and Park Police officers have put me in jail before when I was doing nothing wrong. Because of the intimidation I took down the flags.
15 I used these flags to communicate with the general public. Forcing the removal of my flags has interfered with my communication to the general public.
16 I had the flags up for a long, long time -- now they became illegal according to the opinion of Sgt. J. Paccione, Officer Mitzell, and their "superiors."
Under penalty of perjury,
P.O. Box 4931
Washington, D.C. 20008