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JENNER & BLOCK LLP ANDREW J. THOMAS (Bar No. 159533) ajthomas@jenner.com LISA J. KOHN (Bar No. 260236) lkohn@jenner.com CHRISTINA AVEDISSIAN (Bar No. 288067) cavedissian@jenner.com 633 West 5th Street, Suite 3600 Los Angeles, CA 90071 Telephone: 213 239-5100 Facsimile: 213 239-5199 ACLU FOUNDATION OF SOUTHERN CALIFORNIA PETER J. ELIASBERG (Bar No. 189110) peliasberg@aclu-sc.org 1313 West 8th Street Los Angeles, CA 90017 Telephone: 213 977-9500 Facsimile: 213 977-5299 Attorneys for Plaintiff, EFREN MONTIEL JIMENEZ UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

EFREN MONTIEL JIMENEZ, Plaintiff, v. COUNTY OF SAN BERNARDINO, Defendant.

Case No. EDCV13-02163 DSF (RZx) DECLARATION OF RUDY RAMIREZ IN SUPPORT OF PLAINTIFF’S APPLICATION FOR TEMPORARY RESTRAINING ORDER

Declaration of Rudy Ramirez in Support of Plaintiff’s Application for Temporary Restraining Order

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DECLARATION OF RUDY RAMIREZ I, Rudy Ramirez, declare as follows: 1. I am the President of the Inland Empire Latino Art Association (“IELAA”) and a resident of San Bernardino County. If called to testify, I would and could testify with personal knowledge as to all of the following. 2. Each year, the County of San Bernardino (the “County”) commemorates Hispanic Heritage Month with an art exhibit in the second-floor gallery of the Government Center, located at 385 North Arrowhead Avenue, San Bernardino, CA 92415. For the past five years, I have been personally involved in organizing the Hispanic Heritage Month Art Exhibit, including the 2013 Exhibit. The Hispanic Heritage Month Art Exhibit is hosted by IELAA and the San Bernardino County Hispanic Employees Alliance. The purpose behind the Hispanic Heritage Month Art Exhibit is to showcase the diversity and talent of local artists and educate the general public about the Hispanic creative experience. The first Hispanic Heritage Month Art Exhibit was held in September – October

16 2009, and it has since become a beloved annual tradition within the San 17 Bernardino community. The fifth annual exhibit in honor of Hispanic Heritage 18 Month (the “2013 Exhibit”) opened at the second-floor gallery of the Government 19 Center on September 16, 2013, and is scheduled to run until November 29, 2013. 20 It features over 75 different works of art, representing a breadth of artwork by local 21 Latino artists, from ceramic pieces to oil paintings, sketches of Hollywood stars to 22 a portrait of Jesus, and abstract works to political pieces. 23

3.

Consistent with my role as an organizer of the 2013 Exhibit, a flyer

24 created by IELAA member Brad Borrero and a County press release promoting the 25 2013 Exhibit invited local artists and County employees interested in displaying 26 their artwork at the 2013 Exhibit to contact me. 27

4.

The County has never informed me or the IELAA about any policy or
-2Declaration of Rudy Ramirez in Support of Plaintiff’s Application for Temporary Restraining Order

28 written guidelines governing what art could or could not be displayed at the

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Government Center, and I do not believe the County has any such policy or guidelines. The County has never pre-screened any of the works to be displayed in the Hispanic Heritage Month Art Exhibit. For the past five years, we have displayed all of the artwork submitted by artists in the Hispanic Heritage Month Art Exhibit. For example, one year an artist submitted 15 different pieces and we included all of them in the exhibit. Until this year, the County never told the IELAA that any work could not be displayed or had to be removed from display for any reason. 5. Efren Montiel Jimenez is a Mexican-born surrealist artist, whose paintings have been displayed at numerous exhibitions in Mexico and California. He is an accomplished visual artist and has garnered several awards and distinctions for his paintings over the course of his career, including a recent award at the 64th All-California Juried Art Exhibition at San Bernardino’s National Orange Show. 6. Five of Mr. Jimenez’s paintings were initially displayed at the 2013 Exhibit – “Connection,” “Allegory and Fantasy,” “Enigma,” “Natural Beauty,” and “Day After.” 7. Shortly after the 2013 Exhibit opened on September 16, 2013, I was present when county personnel demanded that three paintings – two paintings by Mr. Jimenez and one painting by artist Armando Aleman – be removed from display in the second-floor gallery of the Government Center. 8. On or about September 17 or 18, 2013, I was putting up artwork in the second-floor gallery of the Government Center. Felisa Cardona, Deputy Public Information Officer at the County, approached Mr. Borerro and me and informed us that three paintings had to be removed from the 2013 Exhibit because “someone complained.” Ms. Cardona identified the three paintings – “Connection” and “Allegory and Fantasy” by Mr. Jimenez and “Prayers to the Gods” by Mr. Aleman.
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EXHIBIT A

Exhibit A Page 5

EXHIBIT B

Exhibit B Page 6

EXHIBIT C

Exhibit C Page 7

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