UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MARY HUDDLE, et al.
       Plaintiffs.

         v.                    Civil Action No. 88-3130
                               Judge Joyce Hens Green

RONALD WILSON REAGAN, et al.
       Defendants.

DECLARATION OF CONCEPCION PICCIOTTO IN SUPPORT OF PLAINTIFFS' MOTION FOR TEMPORARY RESTRAINING ORDER

I, Concepcion Picciotto, hereby declare under penalty of perjury that the following is true and accurate to the best of my knowledge and recollection:

1. On June 1, 1990 at approximately 1:30 PM I was at my demonstration site -- consisting of two signs, two flags, and literature, all of which were used for the purpose of communicating my views and opinions to the general public --on the south side of Lafayette Park, facing the White House.

2. Approximately forty feet to the northwest, and in plain sight from my demonstration, a man had tied two flags and a sign to a park bench.

3. U.S. Park Police Officer Joyner approached me and ordered me to take down my two flags.
4. I asked Officer Joyner, "Why?" He replied, "It's the law." I asked him to show me the law in writing.

5. Officer Joyner just put my two flags on the ground. Officer Joyner did nothing about the two flags and the sign tied to the park bench.

6. After the officer left, I put my flags back.

7. Later, at approximately 3:00 PM there was a large number of Park Police officers in front of my signs waiting for Mr. Gorbachev to arrive, and various small groups of demonstrators crying "Democracy, Freedom."

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8. Several Park Police officers approached my demonstration, and ordered me to put my flags down, telling me that I was in violation of the law. Approximately forty feet to the northwest, and in plain sight from my demonstration, the two flags and sign were still tied to the same park bench. The man who had tied them there was nowhere in sight.

9. I was told, "Do as we say or we will take them down."

10. When I made no move, officer Joyner threw my flags down on the ground.

11. My colleague, William Thomas, who arrived at my demonstration at about that time, put the flags back up.

12. On June 13, 1990, at approximately 8:30 several U.S. Park Police vehicles began to congregate on Pennsylvania Avenue in front of my demonstration site.

13. About half a dozen U.S. Park Police officers, led by Sergeant Gentile, approached me, and I was told to put my flags down.

14. When I asked why, I was first told that the flags could not be attached to my signs.

15. I pointed out that the flags were not attached to the signs, but only resting on them.

16. I was told that they couldn't be resting on the signs.

17. I offered to put the flags in separate stands instead of resting them on the signs.

18. I was told that I would have to put them down.

19. I asked what I could do to satisfy the police that my flags weren't violating anything. I was again told to take my flags down or the police would do it.

19. When I made no move to take the flags down, two officers, one Officer Bacon, each took one flag and put them both into a paddywagon.

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20. To the best of my knowledge and belief there was no probable cause to justify the seizure of my flags.

Under penalty of perjury,

/s/ Concepcion Picciotto
Concepcion Picciotto









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