PLAINTIFF'S EXHIBIT 11-d

On the night of February 24th, 1991, I attended a protest at Lafayette park, across from the White House. There were a series of speakers and then a candle-light vigil to protest the initiation of the ground war in the Persian Gulf. The crowd, approximately fifty to a hundred people, then moved to the section of the park that faces the White House to bolster the ranks of the drumming vigil. There was chanting and drumming, the usual peaceful, non-violent demonstration that has marked the protests in Lafayette park.

Around 6:45 pm the number of park police increased by almost more than double, at one point I counted approximately thirty police; in the mean- time, the size of the protest had diminished to fifty to seventy people. At this point, a couple of police moved to strategic positions in the back of the crowd, encircling the protest. Soon after this maneuver, two police cars parked in front of the protectors and said something over their loudspeaker. The communication was, however, unintelligible. The next series of events happened quite rapidly. Two or three paddy wagons parked next to the police cars bordering the fence that separated the street and the park. There was a flurry of activity where some organizers started coordinating the protest. It was announced that the drummers were going to be arrested. As a response to this we formed a circle around the drummers in an act of non-violent, civil disobedience. I was one of the people who volunteered to act as a part of this "human fence". We linked arms in a circle around the drummers, and prepared ourselves for some sort of police action. Three police men stood directly in front of the section where I was standing with their night sticks drawn. One had a large handle-bar type mustache, and wore a park police helmet. On a signal the police charged the circle. They did not use restraint, let there be no mistake that these police officers were belligerent; they charged, forearms raised and night-sticks in hand. When they charged, I received a forearm to my mouth from the officer with the mustache who I mentioned earlier, and was toppled along with the rest of the people on my side of the circle. I was also stepped on by the same officer as he tried to apprehend the drummers in the center. While on the ground, I looked around and saw people in headlocks, and police throwing punches. Anyone who moved was considered a target. I remember someone screamed, "they'll hit you if you move!"

The people in the center were dragged off, some in choke holds. I saw the police throw unnecessary punches, and excessively restrain three people: one was curled on the ground, one was in a choke hold, and another was thrown on top of the chain link fence. At this point the protesters were gathering around the arresting officers screaming "shame!". To disperse the crowd, and conceal the abuse, six mounted police formed a wall with their horses between the paddy wagon and the protectors. These police also used the horses to intimidate, moving the horses offensively against vociferous protesters. The arrest procedures seemed to take a long time; the protesters being arrested were lying face down on the ground with police surrounding them. At this point there was only verbal exchange between the mounted police and the protesters, other police were protecting the access to the street where the arrest was taking place. Finally all of the police retreated, including the mounted park police, and I left soon after. I would like to note the fact that the protesters in no way instigated the violence that was used. There was only verbal exchange on the part of the protesters, the police unnecessarily used violence to disrupt a peaceful, nonviolent demonstration.

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Exhibit 11 Continued...