Huddle, et. al. ) Plaintiffs pro se ) C.A. No. 88-3130 ) v. ) Judge Joyce Hens Green ) Reagan, et. al. ) Defendants. ) __________________________________)
I, Ellen Thomas, hereby declare under penalty of perjury that the following is accurate and correct to the best of my knowledge and recollection.
1. I have, or have access to, the original tapes from which the accompanying video composite (Exhibit A) was assembled. See attached Exhibit A-1. These originals, if needed, will be available to the Court.
2. Exhibit A was drawn from approximately thirty hours of tape. Perhaps the greatest difficulty I experienced in assembling Exhibit A was in deciding what to leave out.
3. Even though Exhibit A is about 50 minutes longer than I'd have liked, it only begins to sketch a picture which emerges in much finer detail in the unused footage.
4. As is evident from the quality of the video, I did not have access to high quality equipment. I pray that the viewer will seek substance over form.
5. Either Thomas or myself recorded or witnessed each of the incidents portrayed in Exhibit A.
6. I can also identify the persons who were operating the video recorder in the remaining tape not done by Thomas or me.
7. The accompanying videotape portrayal is incomplete.
8. First, it should be noted that we were working with a borrowed recorder. This machine first became available to us on January 26, 1991, but only on a limited basis. On many occasions when there was intense police activity in the park, for example between February 16th and 20th, we had no recorder at all in the midst of hourly threats of arrest "for sleeping."
9. When the camera was available to us, as before, our primary focus continued to be communicating with the public on issues of broad public concern. The newly acquired burden of video documentation came as an unwanted, distracting interference to our vigil activities.
10. Practically, this split of energy between communication and technical video documentation is reflected in the videotape as segments with no predicate to emotional or apparently violent action recorded when Thomas' or my attention happened to be suddenly drawn, from the midst of our communicative activity, to some questionable action involving police officers.
11. Therefore, to gain the added perspective necessary for accurate understanding, a viewer of the videotape should also refer to the declarations of Concepcion Picciotto, Ellen Thomas, William Thomas, Breet ("Song") Hamrick, Scott Galindez, Karin Love Cartwright, Diana Nomad, Allen Tubis, Albert Cole, and Exhibits 1-24 accompanying the Complaint filed herewith.
12. For the most part in the scenes of Park Police sleep detection sweeps, when they knew their acts were being recorded, the police officers involved were on particularly good behavior.
13. I believe that police sensitivity to public scrutiny of their actions is reflected in the "sign seizure" footage on
February 23, 1991, when a Washington Post reporter responded to a telephone call, after Sgt. McNally threatened to arrest me for a small box of literature. The reporter spoke to Sgt. McNally and the threatened enforcement action did not materialize due in large part, I think, to the presence of that reporter.
Respectfully submitted this __th day of March, 1991,
Ellen Thomas, pro se
2817 11th Street N.W.
Washington, D.C. 20001