Case 2:17-cv-00218-RSM-JPD Document 45-14 Filed 02/22/17 Page 1 of 7

EXHIBIT I1
 Case 2:17-cv-00218-RSM-JPD Document 45-14 Filed 02/22/17 Page 2 of 7

1 SUPPLEMENTAL DECLARATION OF LUZ L.

2
I, LUZ L., declare the following:

3
1. I make this declaration based on my personal knowledge, and if called a

4
a witness, I could and would testify to the following matters:

5
2. I am the mother of Daniel Ramirez Medina.

6
3. Daniel has always helped take care of our family. Before he moved t
Washington, Daniel lived with my daughter and me at our home. Since I do not have
7
driver's license, Daniel would help me by taking me to work every single day. H
8
would also help me with the household chores like cooking and doing laundry. Whe
9
his son, Daniel Jr., or I had a medical appointment, he would drive us to the doctor.
10
Financially, Daniel also helped support our family. He always offered to pay or hel
11
pay the bills at home. Daniel also contributed with the rent. In many ways, Daniel wa
12
the man of the house. I felt safer having him with us.
13

14
4. Daniel is a very noble person and is always willing to help others. H
would often go to my sister's house to help her mow the lawn, and when my siste
15
offered to pay him Daniel would decline because he was happy just to help. He als
16
helped people in our community when their cars needed an oil change. And if he sa
17
that someone's car was stopped in the middle of the road, Daniel would take hi
18
jumper cables and help them get on their way.
19
5. My son has a huge heart, which is best seen in the way he has cared fo
20
his son. I remember the day Daniel Jr. was born. Daniel cried because of how happy h
21
was. He saw the baby being born, and I know that it was a very special moment fo
22
him when he heard the baby's first cries. I remember that on that first day at th
23
hospital, Daniel did not want to let anyone, including me, hold the baby because h
24
wanted to keep holding him in his arms. He did not want to let Daniel Jr. go.
25
6. A photograph of Daniel and his son, Daniel Jr., is attached hereto a
26
Exhibit A.
27
7. Daniel Jr. is Daniel's greatest joy, and from the moment Daniel Jr. wa
28
born, Daniel did not want to be away from him. When they returned home from th
 Case 2:17-cv-00218-RSM-JPD Document 45-14 Filed 02/22/17 Page 3 of 7

hospital, Daniel had everything ready for the baby: his cradle, his toys-he wante
2 everything to be perfect. Throughout the mother's days of rest following childbirth
3 Daniel took care of both her and the baby. Daniel and the baby' s mother lived with me
4 so I saw how Daniel would stay up in the middle of the night when the baby wa
5 crying. He would hold him against his chest until the baby settled down and fell bac
6 asleep. I found it very sweet to see how Daniel took care of his son from the day h
7 was born, and how he always wanted to keep him protected.
8 8. My son is an extremely sensitive father and nothing hurts him more tha
9 seeing his son unhappy. Whenever we take Daniel Jr. to the doctor to get his vaccines
IO Daniel asks me to stay in the room while he waits outside because he simply canno
1I tolerate the heartache of seeing Daniel Jr. cry even for something as routine as gettin
12 a shot. It is truly an injustice that Daniel is being detained and made to seem like a ba
13 person because my son would simply never be able to hurt anyone.
14 9. Daniel is a great father who always made time to play with his son. Whe
15 he was living with us, they would both go out to the backyard and play with the bal
16 because that was one of Daniel Jr.'s favorite games. One Christmas, Daniel bought hi
17 son a tablet and downloaded some games into it. Daniel Jr. really loved to sit and pla
18 the games with his father.
t9 10. Daniel loved taking his son out. I remember one time when Daniel invite
20 me to go to the Fresno Zoo with my grandson and him. When Daniel was young, h
21 really loved animals, but I was never able to take him to the zoo. It was really beautifu
22 for me to see that even though it was not something I could do with him growing up
23 he had the opportunity to experience this with his son. Another time, the three of u
24 went on a Catholic pilgrimage to Santa Maria, where we attended Mass to celebrat
25 Christ. Afterwards, we took Daniel Jr. to the beach. That was such a wonderful da
26 because Daniel Jr. had a lot of fun making sand castles, running around the beach, an
27 chasing the seagulls with his father.
28 11. After Daniel left for Washington, he made sure to talk with Daniel Jr
very frequently. It was a little difficult because I do not have a cell phone, so I rely o
 Case 2:17-cv-00218-RSM-JPD Document 45-14 Filed 02/22/17 Page 4 of 7

1 my daughter's cell phone. She is currently attending college, but Daniel would mak
2 sure to arrange times to call when she was home and could hand the phone to Daniel
3 Jr. Daniel almost always set up a video chat so they could see each other while the
4 talked.
5 12. During the weeks that I had Daniel Jr. with me, Daniel would call almos
6 every day, if not every day, to speak with his son. When it was time to drop him off a
7 his mother's house, Daniel would call me to ask if we already dropped him off. Eve
8 while he was away, he was constantly checking in on Daniel Jr.'s well being.
9 13. Since the day Daniel was detained, we have not had peace of mind. I hav
10 felt a lot of support from our community. People see my family and ask us how thing
11 are going with my son, and how they can help us. Even the people in our town that ar
12 not related to us, but who know Daniel and know that he is a good person, tell us swee
13 things to support us.
14 14. In spite of the support we have received, I am no longer able to sleep fro
15 how worried I feel. I cannot be at peace at home, and I cannot work like I used t
16 because I am afraid to go out and be confronted by strangers.
17 15. The situation we are facing has also affected Daniel Jr. in a ve
18 emotional way. I have noticed that since Daniel's detention, Daniel Jr. has become
19 lot quieter, and I know Daniel Jr. really misses the video calls they used to have befor
20 Daniel was detained. Once we are done talking to Daniel when he calls from th
21 detention center, Daniel Jr. comes up to me to ask for his father again. I believe that i
22 hurts my grandson to not be able to see his father.
23
24
25 \\

26
27
28 \\
 Case 2:17-cv-00218-RSM-JPD Document 45-14 Filed 02/22/17 Page 5 of 7

16. I ask God that he return Daniel to his family soon, but mostly to his son.
2 Daniel's release would be an economic relief for our family. Daniel often told me tha
3 he wanted to find a better job in Washington so that I could retire and only dedicat
4 myself to caring for my grandson. I know that if he is released, he will continue t
5 work to find a better job because Daniel has always cared about supporting our family
6 I also believe that if Daniel is set free, my grandson's life will be improve because h
7 will be able to see and talk to his father freely once again. I know that this will mak
8 Daniel Jr. incredibly happy, and for that reason above all else, I want Daniel to hav
9 his freedom.
10
11 I declare under penalty of perjury under the laws of the State of California tha
12 the foregoing is true and correct. Executed on February 22, 2017 at Lindsay
13 California.
14

15 Lv z t? L
16 LUZL.
17

18
19

20

21

22

23
24
25

26
27
28
Case 2:17-cv-00218-RSM-JPD Document 45-14 Filed 02/22/17 Page 6 of 7

Exhibit A
Case 2:17-cv-00218-RSM-JPD Document 45-14 Filed 02/22/17 Page 7 of 7