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AMENDED
EXHIBIT 1
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No.: 1:18-cv-24190

WILLIAM O. FULLER, and
MARTIN PINILLA, II,

Plaintiffs,

v.

JOE CAROLLO, and
JOHN DOES 1-10,

Defendants.
___________________________________/

AMENDED DECLARATION OF WILLIAM O. FULLER IN SUPPORT OF THE
MOTION FOR TEMPORARY RESTRAINING ORDER AND EMERGENCY HEARING

I, William “Bill” O. Fuller declare as follows:

1. I am above the age of 18, and have personal knowledge of the facts set forth

herein.

2. I am a resident of Miami-Dade County, Florida and the Plaintiff in the above-

styled action.

3. I am also the President and Chairman of the Board of Directors of Viernes

Culturales/Cultural Fridays Inc. (“Viernes Culturales”), a non-profit organization.

4. On the Friday of every month, Viernes Culturales organizes and holds a festival

known as Viernes Culturales/Cultural Fridays, in Calle Ocho.

5. The original idea for the festival came from The City of Miami.

6. The City’s Planning Department supported the creation of Viernes Culturales

based upon a Latin Quarter Study and a Little Havana Neighborhood Planning Study, both of
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which recommended that, in order to preserve and enhance the rich culture of Little Havana, a

series of cultural activities including art exhibits, dance, music, poetry, theater, film, and

neighborhood historic tours should be provided to the community.

7. The creation of Viernes Culturales also had the support of the City of Miami

Commission. In fact, then-Commissioner Willy Gort and then-City Administrator Pablo Canton

were two of the Founders of Viernes Culturales. Viernes Culturales currently has both City and

County Commissioners participating on the Board and is sponsored by the Miami-Dade County

Mayor and Board of County Commissioners, as well as The James L. Knight Foundation and

The Cultural Affairs Council.

8. With all of this support, Viernes Culturales has organized a festival incorporating

all of the art galleries, businesses and restaurants along 8th street from 17th Avenue down to

14th Avenue, on the last Friday of every month. The Festival has occurred every month for

eighteen (18) years, since May 26, 2000.

9. Over the course of its history, Viernes Culturales has raised and spent more than

$3 million building the Friday cultural event. Each month Viernes Culturales sends out

thousands of emails to get people to attend. A true and correct copy of a typical advertisement

for the event is attached hereto as Exhibit A.

10. As a result of these marketing efforts, the Festival has become extremely well

known and well attended by more than 5,000 people each month. Of course, the vendors who

participate in the event, as well as the neighborhood stores and shops, have come to rely on the

monthly event for a good portion of their sales and revenues.

11. An integral part of the monthly festival are the activities that take place in

Domino Plaza, which houses over 20 vendors selling original art and handmade crafts and has a

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stage at the back of the park to showcase singers, musicians and other talent from the Little

Havana community. The City has always been exceptionally supportive of the festival and

provided support through the provision of stages and increased police oversight.

12. In recognition of the success the Festival continues to have in revitalizing Little

Havana and supporting the local artists, musicians, dancers, craftsmen, and entrepreneurs,

Commissioner Willy Gort and Mayor Thomas Regalado have awarded Viernes Culturales with a

proclamation from the City of Miami.

13. On at least six occasions over the past year, Viernes Culturales has invited

Commissioner Carollo to come to its events and even to join its Board of Directors meetings.

For example, on March 19, 2018, the Director of Viernes Culturales, acting on my instruction,

sent a letter to Mr. Carollo to invite him to a March 29, 2018 Viernes Culturales Board Meeting.

The purpose of the invitation was to introduce Mr. Carollo to Viernes Cultures Board of

Directors and open a dialogue with Mr. Carollo on Viernes Culturales’ plans and future goals. A

true and copy of the letter is attached hereto as Exhibit B.

14. On April 6, 2018, I sent Mr. Carollo an email, following up on our March 19,

2018 invitation. In my email, I attached a copy of the invitation sent on March 19, 2018, and,

again, invited Mr. Carollo to the April 19, 2018 Viernes Culturales Board Meeting. A true and

correct copy of my April 6, 2018 email is attached hereto as Exhibit C.

15. On August 8, 2018, I sent another email to Mr. Carollo, to again invite him to a

Viernes Culturales Board Meeting, which would be held on September 20, 2018. A true and

correct copy of my August 8, 2018 email is attached hereto as Exhibit D.

16. While the prior emails had been sent by Ms. Pati Vargas at my instruction, on

September 28, 2018, I directly sent an email to Carollo to, again, invite him to participate in a

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Viernes Culturales Board Meeting, which would be held on October 17, 2018. A true and

correct copy of my August 8, 2018 email is attached hereto as Exhibit E.

17. Despite serving as the City’s Commissioner for Little Havana, Carollo never once

even provided the courtesy of a response to these repeated entreaties.

18. On August 3, 2018, I was able to take the sworn testimony of Carollo’s former

Campaign Advisor and District Liaison, Mr. Stephen Miro. Even before Carollo had taken any

action against Viernes Culturales, and unprompted by the questioning itself, Mr. Miro explained

that Carollo was secretly planning to shut it down.

19. Miro’s testimony proved prescient. As shown by documents produced pursuant

to a public records request, Carollo forwarded the invitations to join Viernes Culturales and help

it to Mr. Miro. Mr. Miro forwarded them to Mr. Kuehne and to an email address

quepasalittlehavana@gmail.com. True and correct copies of the emails exchanged by Mr.

Carollo, Mr. Miro, and Mr. Kuehne are attached hereto as Composite Exhibit F.

20. Mr. Kuehne then created a corporation called Que Pasa Little Havana on April 10,

2018, a mere 3 weeks after I invited Mr. Carollo to attend the Viernes Culturales Board of

Directors meeting. A true and correct copy of the articles of incorporation of Que Pasa Little

Havana is attached hereto as Exhibit G.

21. More importantly, Carollo’s efforts to eliminate Viernes Culturales resumed a few

short weeks after Miro’s testimony, as I withdrew an ethics complaint against Carollo. At that

time, in late August 2018, Carollo ordered that Domino Plaza be shut down and physically

barricaded. No public reason was ever given. However, when the security guard at Domino

Plaza was asked why it was shut down, she said it was at the order of the commissioner. Asked

how she knew Carollo had closed it, she said he had come to the site on Thursday to make sure it

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was shut down. Domino Plaza reopened on August 29, 2018, and on Friday, August 31, 2018,

just two hours before Viernes Culturales was set to begin, he ordered it shut again. The excuse

was “pothole repair,” but in reality there were only a handful of tiles that had been removed and

needed to be replaced (and their initial removal was probably at the order of Carollo). In the

midst of all of this, another City Commissioner explained to me that Carollo was targeting the

festival solely to “f*%k with Fuller.”

22. During the 18-year history of the festival, and right up until October 2018,

Viernes Culturales had never applied for or obtained a special events permit in relation to

Domino Plaza, where a key part of the festival occurs, and, despite its heavy involvement in the

Festival, the City has never requested or required Viernes Culturales to pull any type of events

permit.

23. The first time Viernes Culturales applied for a special events permit for use of

Domino Plaza was for the October, 2018 event. The reason Viernes Culturales did so in that

month was because I had learned that Commissioner Carollo was planning to apply for a permit

for himself for that same day, in order to block the Viernes Culturales Festival. Accordingly,

Ms. Pati Vargas, the Director of Viernes Culturales, applied for and was granted a special events

permit for the event on the last Friday of October, 2018.

24. Ms. Vargas had been asked to secure permits for the remaining fourth Fridays of

each month as well. When she submitted the application for the last Friday of November,

however, she was informed by the City that Commissioner Carollo had in fact beaten her to the

punch and filed his application for use of the plaza that same Friday.

25. Specifically, the City stated: “Please be advise [sic] that at this time you [sic]

application for Viernes Culturales for Domino Plaza can’t be process [sic] since the park has

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been reserve [sic] for those days.” A true and correct copy of the November 13, 2018 email from

the City to Viernes Culturales is attached hereto as Exhibit H.

26. Viernes Culturales has since obtained a copy of the application Mr. Carollo

submitted, which he did on November 8, 2018, one day after the election. A true and correct

copy of Mr. Carollo’s application is attached hereto as Exhibit I.

27. The application is submitted in Commissioner Carollo’s own name, rather than

that of Que Pasa Little Havana, and the City Attorney, despite being fully aware of Carollo’s

retaliatory conduct, has rebuffed complaints from Viernes Culturales, stating that Commissioners

have the right to reserve public spaces whenever they want.

28. Carollo’s attempts to shut down Viernes Culturales without any regard for the

history of the institution, whose founding was inspired by the City of Miami and supported for

more than eighteen years by the City, is also done without regard to the real harm that his actions

are causing those who have devoted much of their adult lives to promoting Viernes Culturales.

Among those harmed by Mr. Carollo’s actions is Viernes Culturales Director Ms. Pati Vargas

who is emotionally distraught, and has resigned from her position as Director because she feels

so bad that Mr. Carollo filed his application for the space before she did on behalf of the

organization.

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EXHIBIT A
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EXHIBIT B
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From: Viernes Culturales culturalfridays@gmail.com
Subject: Invitation to next Viernes Culturales Board Meeting
Date: March 19, 2018 at 10:01 AM
To: jcarollo@miamigov.com
Cc: Carole Ann Taylor MIAMITOGO@aol.com, Ginny Gutierrez - GMCVB Ginny@gmcvb.com, Marvin Tapia tapiamarvin@yahoo.com
, Ninoska Perez-Castellon Art ninoskapc@aol.com, Suzanne Batlle suzy@azucaricecream.com, Vivian Greer-Digon
Vivian.Greer-Digon@miamidade.gov, Bill Fuller bill@barlingtongroup.com

Pati Vargas - Viernes Culturales
Little Havana's Monthly Arts & Culture Festival
Futurama Art Galleries, ​ ​ 1637 SW 8th St. # 116 Miami, FL 33135
305.643.5500 www.viernesculturales.org

******

Invitation to
Comm…lo.docx
Case 1:18-cv-24190-FAM Document 21-1 Entered on FLSD Docket 11/21/2018 Page 12 of 47

March 19, 2018
VIA EMAIL AND MAIL
Commissioner Joe Carollo
Miami City Hall
3500 Pan American Drive
Miami, FL 33133
jcarollo@miamigov.com

Re: Invitation to Next Viernes Culturales Board Meeting
Dear Commissioner Carollo:

I would like to invite you to a board meeting for Viernes Culturales that will take place at
Futurama located at 1637 SW 8th Street, Miami, FL 33135 on Thursday, March 29, 2018 at 4:45 pm, we
can also meet at your office if you wish. The purpose of the meeting is to introduce you to our Board of
Directors and open a dialogue with you on our upcoming plans and future goals.

As I am sure you are aware, Viernes Culturales/Cultural Fridays, Inc. is a nonprofit organization
which coordinates the popular Viernes Culturales/Cultural Fridays art, music and culture festival. Our
events are held on the last Friday of every month in the heart of Little Havana, on Calle Ocho between
13th and 17th Avenues, from 7-11 pm.
The idea for Cultural Fridays originated from The City of Miami Planning Department with the
support of the City of Miami Commission, in collaboration with The Latin Chamber of Commerce, Little
Havana Development Authority, merchants, residents, design professionals and community leaders. A
City of Miami Planning Department 1984 Latin Quarter Study and 1994-96 Little Havana Neighborhood
Planning Program recommended that a series of cultural activities and events including art exhibits,
dance, music, poetry, theater, film, and neighborhood historic tours should be promoted all year round in
order to preserve and enhance the rich culture of Little Havana. The first Cultural Friday was held on May
26, 2000 and approximately 2,000 people attended. Since then, internationally known artists have
participated and supported Viernes Culturales/Cultural Fridays.
Cultural Fridays is targeted to all those who enjoy arts and culture. Our audience is multicultural
and represents the ethnic diversity of our South Florida community. Anyone who enjoys live music,
dancing under the stars, art galleries, domino games, cigar rollers, local arts and crafts and delighting in
the wonder that is Little Havana is more than welcome to be a part of Cultural Fridays!
Over the years, Viernes Culturales has provided a forum for residents of Little Havana to foster a
sense of community in the area where they live; to communicate more effectively the needs of our
neighborhood to city officials such as yourself; and to encourage residents to work together to keep our
neighborhood an attractive and safe place to live.

1637 SW 8th Street, Miami, FL 33135
Case 1:18-cv-24190-FAM Document 21-1 Entered on FLSD Docket 11/21/2018 Page 13 of 47

I hope you will come to meet the dedicated and talented members of our board and to engage
with all of us to come up with a plan on how to work together to ensure that Viernes Culturales continues
to remain an integral part of the Little Havana experience.

If you have any questions regarding this meeting, please call me at 305-643-5500.
Thank you for your time, and I hope to see you at the meeting.

Sincerely,

Pati Vargas
Director, Viernes Culturales

1637 SW 8th Street, Miami, FL 33135
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EXHIBIT C
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From: Viernes Culturales culturalfridays@gmail.com
Subject: Second Request: Fwd: Invitation to next Viernes Culturales Board Meeting
Date: April 6, 2018 at 9:31 AM
To: jcarollo@miamigov.com
Cc: Carole Ann Taylor MIAMITOGO@aol.com, Ginny Gutierrez - GMCVB Ginny@gmcvb.com, Marvin Tapia tapiamarvin@yahoo.com
, Suzanne Batlle suzy@azucaricecream.com, Vivian Greer-Digon Vivian.Greer-Digon@miamidade.gov, Ninoska Perez
artbyninoska@gmail.com, Bill Fuller bill@barlingtongroup.com

Good morning Commissioner Carollo, I hope this email finds you well. Attached is an invitation the Board
of Viernes Culturales extended last month to you and would like to extend to you once again. Our next
Board meeting is Thursday, April 19 at 4:45 pm at our offices. If you would rather the Board can meet you at
your offices. Thank you very much for your time.

Pati Vargas - Viernes Culturales
Little Havana's Monthly Arts & Culture Festival
Futurama Art Galleries,1637 SW 8th St. # 116 Miami, FL 33135
305.643.5500 www.viernesculturales.org

******

---------- Forwarded message ----------
From: Viernes Culturales <culturalfridays@gmail.com>
Date: Mon, Mar 19, 2018 at 10:01 AM
Subject: Invitation to next Viernes Culturales Board Meeting
To: jcarollo@miamigov.com
Cc: Carole Ann Taylor <MIAMITOGO@aol.com>, Ginny Gutierrez - GMCVB <Ginny@gmcvb.com>, Marvin Tapia
<tapiamarvin@yahoo.com>, Ninoska Perez-Castellon Art <ninoskapc@aol.com>, Suzanne Batlle <suzy@azucaricecream.com>,
Vivian Greer-Digon <Vivian.Greer-Digon@miamidade.gov>, Bill Fuller <bill@barlingtongroup.com>

Pati Vargas - Viernes Culturales
Little Havana's Monthly Arts & Culture Festival
Futurama Art Galleries, ​ ​ 1637 SW 8th St. # 116 Miami, FL 33135
305.643.5500 www.viernesculturales.org

******
Case 1:18-cv-24190-FAM Document 21-1 Entered on FLSD Docket 11/21/2018 Page 16 of 47

Invitation to
Comm…lo.docx
Case 1:18-cv-24190-FAM Document 21-1 Entered on FLSD Docket 11/21/2018 Page 17 of 47

EXHIBIT D
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From: Viernes Culturales culturalfridays@gmail.com
Subject: VIERNES CULTURALES BOARD MEETING INVITATION
Date: August 8, 2018 at 5:13 PM
To: Commissioner J.Carollo jcarollo@miamigov.com
Cc: Bill Fuller bill@barlingtongroup.com, Carole Ann Taylor miamitogo@aol.com, Ginny Gutierrez - GMCVB Ginny@gmcvb.com,
Greer-Digon, Vivian (MDPR) Vivian.Greer-Digon@miamidade.gov, Marvin Tapia tapiamarvin@yahoo.com,
Ninoska Perez Castellon artbyninoska@gmail.com, Suzanne Batlle suzy@azucaricecream.com

Dear Commissioner Carollo,

On behalf of the Viernes Culturales board, I would
like to extend an invitation for you to attend our
next monthly board meeting. The board strongly
values your input in the planning of its future
activations. Our next meeting will be held on
Wednesday, September 20th at 4pm. The meeting
will be held at 1637 SW 8th Street. We look
forward to your response.

Sincerely,

Pati Vargas
Director, Viernes Culturales

Little Havana's Monthly Arts & Culture Festival
Futurama 1637 Art Galleries,1637 SW 8th St. Miami, FL 33135
305.643.5500 www.viernesculturales.org
Case 1:18-cv-24190-FAM Document 21-1 Entered on FLSD Docket 11/21/2018 Page 19 of 47

305.643.5500 www.viernesculturales.org

******
NEXT VIERNES CULTURALES, FRIDAY AUG. 31, 2018 | 7- 11 PM
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EXHIBIT E
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From: Bill Fuller bill@barlingtongroup.com
Subject: Invitation - Viernes Culturales Board Meeting October 17th @ 3pm
Date: September 26, 2018 at 10:55 AM
To: jcarollo@miamigov.com
Cc: Viernes Culturales culturalfridays@gmail.com, Maru Lanao maru@barlingtongroup.com, Carole Ann Taylor miamitogo@aol.com,
Ginny Gutierrez - GMCVB Ginny@gmcvb.com, Ninoska Perez Castellon artbyninoska@gmail.com, Marvin Tapia
tapiamarvin@yahoo.com, Suzanne Batlle suzy@azucaricecream.com, jcigar@aol.com

Dear Commissioner Carollo,
Viernes Culturales aims to reinforce its mission of promo2ng Li5le Havana as well as being
the liaison between the ar2s2c community, residents, businesses, and visitors. As we
approach 2018’s last quarter, we look forward to implemen2ng crucial changes, enlis2ng
the support of neighbors and business owners, and strengthening important rela2onships.
Our last mee2ng, which took place on September 19th , welcomed City of Miami Mayor,
Francis Suarez and Esteban Ferreiro, Chief of Staff for Commissioner Manolo Reyes. They
will both appoint a member of their team to a5end all board mee2ngs henceforth. Also in
our last mee2ng, we welcomed Miami Dade College Interamerican Campus President,
Malou C. Harrison, and Miami filmmaker and entrepreneur Joe Cardona as the new
members of the board.
Through the years, Viernes Culturales has had a posi2ve impact on the neighborhood and
the community. The Board of Directors plays a central role in this important work. Because
of your experience and involvement with our community , we invite you to become a part
of this growing tradi2on. The board strongly values your input.
Our next mee*ng will be held on Wednesday, October 17th at 3 pm at 1637 SW
8th Street.
We look forward to hearing from you,
Bill Fuller
Chairman
Viernes Culturales
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COMPOSITE
EXHIBIT F
Case 1:18-cv-24190-FAM Document 21-1 Entered on FLSD Docket 11/21/2018 Page 23 of 47
From: Miro, Steven <SMiro@miamigov.com>
Sent: Wednesday, April 18, 2018 7:13 PM EDT
To: ben.kuehne@kuehnelaw.com <ben.kuehne@kuehnelaw.com>
Subject: Fwd: Invitation to next Viernes Culturales Board Meeting
Attachment(s): "Invitation to Comm Carollo.docx"

Get Outlook for Android

From: Miro, Steven
Sent: Monday, March 19, 11:22 AM
Subject: Fwd: Invitation to next Viernes Culturales Board Meeting
To: carollojoe@hotmail.com

Get Outlook for Android

From: Carollo, Joe (Commissioner)
Sent: Monday, March 19, 2018 10:50:30 AM
To: Miro, Steven
Subject: Fwd: Invitation to next Viernes Culturales Board Meeting

Get Outlook for Android

From: Viernes Culturales <culturalfridays@gmail.com>
Sent: Monday, March 19, 2018 10:01:50 AM
To: Carollo, Joe (Commissioner)
Cc: Carole Ann Taylor; Ginny Gutierrez - GMCVB; Marvin Tapia; Ninoska Perez-Castellon Art; Suzanne Batlle; Vivian Greer-Digon;
Bill Fuller
Subject: Invitation to next Viernes Culturales Board Meeting

Pati Vargas - Viernes Culturales
Little Havana's Monthly Arts & Culture Festival
Futurama Art Galleries,
​​
1637 SW 8th St. # 116 Miami, FL 33135
305.643.5500 www.viernesculturales.org

******
Case 1:18-cv-24190-FAM Document 21-1 Entered on FLSD Docket 11/21/2018 Page 24 of 47
From: Miro, Steven <SMiro@miamigov.com>
Sent: Wednesday, April 18, 2018 7:15 PM EDT
To: quepasalittlehavana@gmail.com <quepasalittlehavana@gmail.com>
Subject: Fwd: Invitation to next Viernes Culturales Board Meeting
Attachment(s): "Invitation to Comm Carollo.docx"

From: Viernes Culturales <culturalfridays@gmail.com>
Sent: Monday, March 19, 2018 10:01:50 AM
To: Carollo, Joe (Commissioner)
Cc: Carole Ann Taylor; Ginny Gutierrez - GMCVB; Marvin Tapia; Ninoska Perez-Castellon Art; Suzanne Batlle; Vivian Greer-Digon;
Bill Fuller
Subject: Invitation to next Viernes Culturales Board Meeting

Pati Vargas - Viernes Culturales
Little Havana's Monthly Arts & Culture Festival
Futurama Art Galleries,
​​
1637 SW 8th St. # 116 Miami, FL 33135
305.643.5500 www.viernesculturales.org
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EXHIBIT G
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EXHIBIT H
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Tuesday, November 20, 2018 at 5:49:15 PM Eastern Standard Time

Subject: Fwd: Viernes Culturales
Date: Tuesday, November 20, 2018 at 4:35:59 PM Eastern Standard Time
From: Jeff Gutchess
To: Bernardo Nacouzi de Mello Franco
AFachments: image001.png, image003.png

Begin forwarded message:

From: Bill Fuller <bill@barlingtongroup.com>
Subject: Fwd: Viernes Culturales
Date: November 14, 2018 at 1>30>13 AM EST
To: "jeff@axslawgroup.com" <jeff@axslawgroup.com>
Cc: "mbernh1031@gmail.com" <mbernh1031@gmail.com>

Bill Fuller
305-525-7662

Begin forwarded message:

From: Viernes Culturales <culturalfridays@gmail.com>
Date: November 14, 2018 at 2:09:51 AM GMT+1
To: Bill Fuller <bill@barlingtongroup.com>
Subject: Fwd: Viernes Culturales

Begin forwarded message:

From: "Orta, Aylin" <AOrta@miamigov.com>
Date: November 13, 2018 at 10:34:48 AM EST
To: "culturalfridays@gmail.com" <culturalfridays@gmail.com>
Subject: Viernes Culturales

Good Morning

Please be advise that at this Pme you applicaPon for Viernes
Culturales for Domino Plaza can’t be process since the park has been
reserve for those days. Also the cut off day for Art Basel days were
11/9/2018. Please accept our apologies.

Sincerely yours

Page 1 of 2
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DEADLINE FOR ART BASEL NOVEMBER 9TH 2018

Aylin Orta
Administra.ve Clerk
City of Miami
Office of Communications
Divisiont of Film and Entertainment,
2nd Floor
Office: (305)416-1322
aorta@miamigov.com

ANY EVENT NEEDS TO ABIDE BY THE NOISE ORDINANCE CHAPTER 36;
SECTIONS 36.1, 36.4, 36.5

“Serving, Enhancing and Transforming our Community”

Follow us on Facebook and TwiFer

Please take a moment to let us know how we are doing at
the City of Miami Office of Film and Entertainment by
clicking the link that applies below:
Film Office
Special Events

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Related Interests