Mailing: 4216 South Mooney Boulevard PMB 136 Visalia, California 93277 LAW OFFICES OF MELO AND SARSFIELD LLP (559) 732-3000 (559) 732-3005 . I Email: lIE'l I . Web: February 26, 2018 Joe Carlini, City Manager, City of Tulare Carlini@tulare.ca.gov City Council, City of Tulare 411 East Kern Avenue, Tulare, California 93274 Re: Tulare Ordinance VIA EMAIL AND US MAIL Dear Mr. Carlini and Council Members, The Law Of?ces of Melo and Sars?eld LLP is a law ?rm that practices in the area of civil rights, First Amendment Constitutional issues and voting cases. We represent a group of Tulare City residents. These residents are supporters of Matt Darby, candidate for the of?ce of Tulare County District Attorney. In exercise of their First Amendment rights to free speech and in order to show their support for Mr. Darby, our clients wish to display signs and other campaign paraphernalia on their private property within the jurisdictional boundaries of the City of Tulare. Tulare City Ordinance 10.188050, et seq, prevents them from exercising these rights. Ordinances such 10.188 have been ruled to be unconstitutional. See Reed v. Town of Gilbert, 135 S. Ct. 2218 (2015); City ofLadue v. Gilleo, 512 US. 43 (1994). Despite these clear Supreme Court rulings, the City of Tulare has taken no action to repeal these laws which are invalid on their face. Continued enforcement of such clearly unconstitutional provisions not only chills free speech, it also suppresses votes. Public expression of one?s political views is a fundamental right which is being denied and infringed by the City. Public debate and public support of candidates such as support for Mr. Darby is a cornerstone of political engagement. Therefore, on behalf of our clients, we demand that the City of Tulare take immediate steps to repeal these unconstitutional provisions and immediately cease any enforcement of same. As the prevailing party in this dispute, we are entitled to reasonable attomey?s fees and costs. We will submit a bill separately. Additionally, we demand that the City of Tulare conduct voter education to undo the damage which your unconstitutional ordinance has done. Should the City of Tulare refuse such reasonable requests, my clients will be seeking judicial enforcement of their rights. I have included a draft of the lawsuit which we will be ?ling with the Tulare County Superior Court should the City of Tulare continue to promulgate such unconstitutional laws. We look forward to your reply in all due haste. Very truly yours, LAW OFFICES OF MELO AND SARSFIELD LLP By: ana?g Lise/(nip Encl: Draft Complaint Page 2