UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE and PHILIP JOSEPH, et. al., )
                                        )
          versus                        )  CA 88-3130-JHG
                                        )  Judge Joyce Hens Green
RONALD WILSON REAGAN, et. al.,          )
                   defendants           )
________________________________________)

DECLARATION OF JEFFREY BROWN

I, Jeffrey Brown, aka "Nakita," hereby declare under penalty of perjury that the following is true and correct to the best of my knowledge and recollection:

1) On Monday, October 30, 1989, at approximately 10:30 P.M., United States Park Police Officer (USPPO) Marsh informed me (Jeffrey Brown) that I could not have plastic covering myself or my personal belongings.

2) I informed USPPO Marsh that it was going to rain, and that I was not in violation of any state laws, but that I would remove the plastic.

3) About this time USPPO Marsh turned off his motorcycle and started towards my signs.

4) About this time Joe, Mike, and Rick l/ came over to inquire what was going on. United States Police Officer Marsh informed us that while he "was on duty, he was the law, and we were to obey his orders," or words to that effect.

5) He also informed Rick that as far as he (USPPO) was concerned, he didn't care about his job, and that he would take his badge off right now "and kick off in yo' ass."


l/ Joseph Vigorito, Michael Cronin, and Rick Hartshorn

6) On November l0, l989, USPPO Dahl started tearing my plastic off me. I informed USPPO Dahl that my plastic was legal and that he, USPPO Dahl, had no right to rip my plastic. USPPO Dahl then pulled out his night stick and said if I take one step forward he would hit me.

7) Joe came up to my sign to inquire what was going on and asked for a Sergeant. Sgt. Gonzalez was called for and assured me that my plastic was legal.

8) I gave Sgt. Gonzalez my word that I would not say anything to USPP Officer Dahl to upset him.

9) USPPO Dahl was not content. After Sgt. Gonzalez left he kept on harassing me. He kept putting his foot on my sign and saying "you think you won." And he called me lazy and said that I was not capable of working a real job, and that's why I was in the park. So I called Sgt. Gonzalez three times before she came again. I told her that USPPO Dahl was harassing me when there was no probable cause.

10. If I had answered him I would have been adding fuel to the fire. Since he was upset that I called his Sgt. every twenty minutes. He was at my sign intimidating me until Five-fifty AM. Sgt. Gonzalez left two USPP officers in the park that night.

11. All night long USPP Officer Dahl kept trying to harass me, and informed me that he had called his buddy who was coming on duty next to "keep up the pressure."

Respectfully submitted,

________________________
Jeffrey Brown
P.O. Box 27217,
Washington, D.C. 20038
(202) 462-0757